ML20211F636
| ML20211F636 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/30/1987 |
| From: | Goodkind M LONG ISLAND LIGHTING CO., Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#187-2586 OL-5, NUDOCS 8702250154 | |
| Download: ML20211F636 (123) | |
Text
{{#Wiki_filter:2 S P6 O 1GND 77ggggyqgy OF PRDCEEDE.7 Y ~ 8 24 P3 :15 UNITED STATES OF AMERICA (F, uD:,. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ____ _____ _ _ _ _ _ _ _ _ _ _x In the Matter of: Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise) (Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL) Unit 1) ( _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x \\^ DEPOSITION OF MARY GOODKIND New York, New York Friday, January 30, 1987 ACE-FEDERAL REPORTERS, INC. Sterwtype Ravrters 444 North Capitoi Street Washington, D.C. 20001 (202)347-3700 s Nationwide Coverage 800-336-6646 G702250154 070130 PDR ADOCK 050003P2 l'DH l3
l q/30/87439.0 i UNITED STATES OF' AMERICA 3. R&T,JonWalsh NUCLEAR REGULATORY COMMISSION 2 ATOMIC SAFETY AND LICENSING BOARD 3
X 4
In the Matter of: 5 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-5; (EP Exercise) 6 (Shoreham Nuclear Power Station,
- (ASLBP No. 86-533-01-OL)
Unit 1) i 7 _________________________________-_x 8 DEPOSITION OF MARY GOODKIND 9 New York City, New York. la Friday, January 30, 1987 11 Deposition of MARY GOODKIND, called for examina-() 12 tion pursuant to notice, at the Federal Emergency Management la Agency, 26 Federal Plaza, New York City, New York, at l 14 1:17 p.m., before Garrett J. Walsh, Jr., a Notary Public 15 in and for the Commonwealth of Virginia at Large, when were l i 16 present on behalf of the respective parties: 17 MICHAEL S. MILLER, ESQ. GOEFFREY KORS, ESQ. l 18 Kirkpatrick & Lockhart 9th Floor, South Lobby i 19 1800 M Street, N. W. Washington, D. C. 20036-5891 20 On Behalf of the Intervenor, the County of Suffolk, State of New York 21 22 I
2 7-1(/- 1 APPEARANCES: '(Continuing) ' 2 JESSINE A. MONAGHAN, ESQ. Hunton & Williams 3 707 East Main Street. P. O. Box 1535 4 Richmond, Virginia 23212 On Behalf of the Applicant, the Long Island' 5 . Lighting Company 6 WILLIAM R. CUMMING, ESQ. Federal Emergency Management Agency-7 500 C Street, S.W. Washington,.D. C. 20472 8 9 10 11 12 13 14 15 16 17 18 19 i 20 21 6 22 l i
2-A C) v 1 C0NTENTS 2 3 Mary Goodkind 4 Examination by Mr. Miller........... Page 3 5 6 7 8 9 EXHIBIT 10 Goodkind Exhibit Number 1 For Identification, Page 5 l 11 ' ~ 12 13 14 15 16 17 l 18 19 20 21 22 O
3 T's V 1 PROCEEDINGS 2 (1:17 p.m.) 3 Where upon, 4 MARY E.
- GOODKIND, was called as a witness, and having first been duly sworn, 5
testified as follows: 6 i 7 DIRECT EXAMINATION 8 BY MR. MILLER: 9 Q Good af ternoon, Ms. Goodkind. My name is Michael to Miller. With me is Geoffrey Kors, with the firm of 11 Kirkpatrick & LocKhart. We represent Suf folk County in O k/ the licensing proceedings before the Nuclear Regulatory 12 13 Commission regarding the Shoreham Plant. 14 First of all, I appreciate very much your 15 rearranging your schedule to be available this af ternoon 16 for this deposition. As you probably know by now, the 17 deposition of the FEMA witnesses extended a bit beyond what 18 we had estimated, and again, we appreciate your accommodating 19 us in this regard. 20 A You are welcome. 21 0 In terms of this deposition, I will be asking l 22 you questions regarding your retention by LILCO as an O
4 qv i expert witness, and your contemplated testimony with 2 respect to issues raised by the Government in contentions 3 filed concerning the February 13th 1986 exercise at the 4 Shoreham Plant. 5 For purpose of my questions, I will try to use 6 the term, ' exercise' to re fer to the February 13, 1986 7 exercise, and that will be my shorthand reference if that 8 is okay with you. 9 A Fine. 10 0 If you have any questions of me during the. course 11 of the deposition, or if you want clarification of any Di 12 matters that I may ask about, please tell me and I will be 13 gl-ad to try to reach a common understanding with you so 14 that we have a common understanding in our questiono and 15 answers. 16 MS. MON AGIIAN : Mr. Miller, before you begin 17 your questions of Ms. Goodkind, I would like to state for 18 the record that Ms. Goodkind was available this morning at 19 9:30 as you previously,noted. As I stated to you in 20 our discussions concerning this depostion yesterday 21 evening, she is available up until six o' clock this evening, 22 and then must leave for the airport for an appointment she l
I e 5 1 has in Chicago. 2 1R. MTT.TFR: Let me have marked as Goodkind Exhibit No' 1 ~ 3 a copy of a two'page:docunent whichiappears to be' the' resume of Mary E. 4
- Goodkind, indexx 5
(The' docunent. referred to is marked as a Goodkind Exhibit No. 1 for identification.) 7 BY MR'. MIILER: (Continuing) - 8 Q And let'me ask you; Ps. Goodkind, if thi' is a resume prepared s 9 by you,.in fact?. i 10 A Yes', it.is.- i l 11 Q Is it a true and correct. resume In terms of the matters f 12 contained therein? 13 A Yes, it is. 14 Q Can you tell me when this resune was prepared? 15 A It was prepared about one month ago. 16 Q Was it prepared in connectiCn with your retention by LILOO? l i 17 A Yes'. f 18 Q Who are you~cmployed by? 19 A I an employed by Impell Corporation in the liidwest Region l 20 Office, located ~ in Bannockburn, Illinois. l l 21 Q I suppose I should ask you if you would state your name and l 22 address for the record. It should be my first question. O ^ "v =eme te "erv cooaktea. t reside ee 821 111chizan a -
y. j i '6 v) 1 Avenue, Evanston, Illinois. 2 Q How long have you been employed by Impell? 3 A Almost exactly one year [' 4 Q And what is your job at Impell? j/ '9 e 5 A My title is Lead Senior Engineer and orie, of'riyi 6 primary current assignments is emergency planner,,, and what J 7 they refer to as Project Engineer for Commonwedith" Edison. 8 Company. 9 I am assisting them with emergency planning s to activities at their nuclear plant sites. [ 11 Q What sites are those? 4 ,e s \\) t 12 A My primary effort at the current time ir, at d 13 the Quad Cities nuclear station. This station is locibhd J. - 14 on the border between Illinois and Iowa, and I have been,_, 6 15 particularly assisting counties in Iowa and the Ctate of 16 Iowa. ^ 17 Also provide other assis tance as needed' to" 18 Commonwealth Edison to assist them in emergency planning. 19 These duties might include providing public information to 4 20 groups such as schools, industries, fire departments; 21 providing general assistance and education and training, 22 and public information, in addition to writing operating o 1 I
j;, l)' 4+ - n : y s O w C. 7 we ,, x e 1 Procedures.
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'/ t / O Can you tell me approximately when you were 2 3 retained'by LILCO in connection with the upcoming litigation? 3
- A Cl4 4
(Witness confers with Ms. Monaghan.) A' I have been retained by Hunton & Williams, and-5 6, that relationship has been official I would say for about 7 three weeks. /1 8 Q Prior to your retention by Hunton & Williams, + - Pr- .+: 9 have you ever performed any duties of any kind relating to l'io the Shoreham Plant? T A Would you repeat the question? I. am not sure -- 11 4 b 12 Q Have you ever performed any dutkes, tasks, ^ ' n> consulted 'for, whatever, with respect to Shoreham prior to 1 14 being ret.hined by Hunton & Williams approximately three i. 1 weeks ago? h 't 16 A. No. p 17 Q In your -- in connection with your job at Impell, t is do you work with the Impell Office on Long Island? I ,i 19 A No. 20-Q Do you know a Mr. Dennis Behr? l 21 A I have met him yesterday when I was here. I just l 22 met him brie fly. 1 LO l c s / 'f e r - + + =.-- g-ar*- -e w e p- _m._,m-%m-cre.-.p. .,-er, ,w,----., ,n.%,,,,e 7.- w, <i.-,-e.,, , - - = ,r,,c.-,,-., ,-e,--,,- ,w-
D .~__- - _ ~t i L e / 8 i Q a Have you met wida any employees or other i Dt 1 V 2 representatives of LILCO with the exception of counsel? JL I met with Mr. Aidikoff while Ms. Monaghan was l 3 4 with us in a meeting. 5 0 Was that yesterday also? A. Yes. 6 r 1.s 7 MR. MILLER: Let's go off the record for a i j 's, second, Joe. 9 (Off the record discussion ensues.) i BY MR. MILLER: (Continuing) m 10 11 Q Now, you have met with Mr. Aidikoff and Mr. 12 Dehr yesterday. Ila've yoa, met with anyone else at LILCO i 13 or who consults for LI,LCO? 1- .( 34 A I have not met anyone else'from LILCO. Anyone else I met was very much in. passing. Nothing more than. 15 an exchange of names, and maybe just a brief description of 16 i 17 . what their involvement may be. 18 Q Could you tell me what the purpose of yesterday's i 19 meeting was? A I wanted to discuss with Ms. Monaghan what the 20 21 testimony might be that I would be preparing, and I wanted Y to have the opportunity to question Mr. Aidikoff about 22 ( i I
..m 9 4 I some aspects of the planning at LILCO. 2 Q You wanted this opportunity with respect to Mr. 3 Aidikoff, but not Mr. Behr? 4 A I had no particular interest in talking with Mr. 5 Behr. 6 Q What was your interest in talking with Mr. 1 7 Aidikoff? 8 A This meeting was arranged by Ms. Monaghan in order t 9 to give me the opportunity to get a more indepth understand-10 ing of what took place during the exercise, and to understand 11 more about the LERO organization. I 12 Q Is it fair to say your meeting with Mr. Aidikoff ~ T 13 was more or less a meeting.to bring you up to speed on LERO 14 and the LERO training program? 15 A At least to some extent. 2 16 Q What else would it have been at that meeting? 17 A Well, I would' tend to say it was one source of I information that I was using, 16 19 Q Information? What kind of information? 1 4 20 A Well, I reviewed several documents in order to 21 prepare for presentation of testimony, and talking with 22 Mr. Aidikoff was another source of information for me. O
10 4 1 0-What is your anderstanding about who Mr. Aidikoff 2 is? A It is my understanding that he. is very well 3 4 informed about the organization of emergency planning.at LILCO. 5 I am not aware of his specific title. 6 7 Q Does Mr. Aidikoff have his own consulting company? 8 A I do not know. 9 Q Do you think he is a LILCO employee? 10 A - Yes. 11 Q Did you discuss the LERO plan with Mr. Aidikoff, / 12 or provisions of the LERO training program, or both? 13 A I would say both. 14 Q Have you at thi's point in time, read or reviewed 15 the LILCO Plan with respect to offsite emergency matters at Shoreham? 16 17 A No. 18 Q Have you read or reviewed any of the implementing i 19 procedures? 20 A I haven't reviewed the documents themselves. I ( 21 have reviewed how the Plan is organized, and how training l l 22 is conducted, what types of materials are used, but only s e e r-y w ww-,-, - - - < - - - e--.--m..-- +=,-,m-y. erg "~~r-m*--+->r-mt-r----m++--e* ev--we--*=-a++-er --++**-+w- 'r-----w'- t-w.
4 11 0h %s 1 in general. 2 I have not reviewed specific training materails - 3 or specific procedures. 4 Q What have you reviewed that tells you how the 5 LILCO Plan is organized? A How the plan is organized? 6 7 Q I thought you just told me that you reviewed how 8 the plan is organized? 9 A I reviewed in general how emergency protective 10 actions would be carried out in the transition phase, under 11 the transition phase, so that I have an understanding of how l 12 the LERO organization would function without the present 13 cupport from State and counties. 14 Q What have you reviewed that has given you this 15 understanding? Is it a document or documents that you have reviewed? 16 17 A I have reviewed several documents, and then I have 18 also questioned Mr. Aidikoff at length. Ms. Monaghan has l 19 provided me some information. 20 Q Could you give me a listing of the documents you 21 recall having reviewed? l 22 A I reviewed the Post Exercise Assessment, the FEMA i { 8 r,- a,-, ,,,,,,,c7-, ---e,..-,.,- en s--- m.y--,e - - - + .---,,..w.., m. ---.-,------m-ye--,y--,-r-
12 RAC Review. 1 2 Q Of Revision 7 and 8? A Yes. I reviewed the contentions. And in 3 preparation for preparing testimony, I have reviewed a 4 number of standard reference materials with which iI am generally 5 f amiliar, but I have re-examined them. 6 7 Specifically, NUREG 065 4. All of the current 8 Operative FEMA guidance memoranda, plus one draft memoranda, 9 FEMA guidance memoranda, known as Ex. 3. Q Can you think of any other documents that you have 10 reviewed at this time? 11 () A I reviewed two letters from Ms. Monaghan that 12 present some initial outline of what may be addressed in is 14 testimony. Q Anything else? 15 A I have looked briefly at some previous exercises 16 where I have been an evaluator or a controller. 17 18 Q And what was the purpose of that review? 19 A I anticipate that part of my testimony will be comparing the performance that was shown during the 20 exercise at Shoreham, with what I have observed at other 21 exercises. 22 Is-
13 O Q Is it fair to say, Ms. Goodkind, that you 1 2 anticipate rendering testimony in which.you would compare the performance of LERO personnel: during the exercise to the 3 4 performance of other personnel at other exercises? A Yes. 5 0 And I assume that would be in a training context? 6 A
- Yes, 7
3 O Is it your opinion that you can draw conclusions 9 about the accuracy of a training program from the performance of individuals during a FEMA-graded exercise? 10 A I think you can draw some conclusions.provided you 11 have enough information available on which to base that 12 conclusion. 13 14 And I say that -- to give an example, the way FEMA does its evaluation, they might cite one or two 15 instances when training did not appear to be effective, but 16 l 17 they may not tell you what the be.se of that sample was, so 18 that you may not know whether they interviewed two people, 19 and two people were unaware of their function, or whether 20 they interviewed five hundred people, and found two out 21 of the five hundred. l l j 22 So, in general, yes, I believe if an evaluation O
14 !% >i 1 is properly written, and gives you enough information, it 2 is some indication of how effective training is. 3 Q You have reviewed the FEMA Post Exercise 4 Assessment Report for Shoreham. I usually call that the 5 FEMA Report, to save words. 6 Is it your opinion that the FEMA Report for the 7 Shoreham exercise permits one to draw conclusions about 8 the accuracy of the LERO training program? 9 A Yes, I think some conclusions can be made. 10 0 Would you just describe for me the conclusions 11 that you think can be drawn from the FEMA Report? ,/'T k/ A Well, I see from the report that FEMA evaluated 12 13 a number of very important elements in emergency planning. 14 The elements that are probably most essential in carrying 15 out a protective action. 16 And from my examination of what FEMA found, I 17 believe that they had very positive things to say for each 18 one of those functions, and it is my feeling that FEMA's 19 evaluation shows a very effective training program in most 20 respects. 21 Q Now, from your review of the FEMA Report, are I 22 there any functions which you believe the FEMA Report would [} l s-I
15 ,V 1 indicate the contrary, that there are problems with the 2 LERO training program? 3 A There are instances cited by FEMA that additional 4 training is needed, or possibly change in procedures. I 5 would see these really as an indication that training needs 6 to be fine-tuned, or that the training needs to take 7 advantage of what was learned during the exercise. 8 Q Can you give me a listing of those areas where you 9 think training needs to be either fine-tuned to take advantage 10 of those areas noted by FEMA during the exercise? 11 A It was shown that the Emergency News Center, there () l 12 was some unnecessary delays, and LERO by changing procedures, is has circumvented the chain of events that resulted in un-14 acceptable delays, so I think in this case a change in 15 Procedure has eliminated some of the training difficulties. 16 That by setting up a system by which information 17 can go directly to a computer display, they have reduced the 18 need for training of as many people at the Emergency News i 19 Cen te r. 20 0 Can you think of any other examples other than the 21 Emergency News Center? 22 A In the instance of the impediments, you know the a L
16 (,; 1 instances to which I am referring; the fuel truck and the 2 gravel truck. It is my understanding that agreements earlier 3 with regard.to FEMA review of the plan had -- there had 4 been a concurrence that major impediments were so unlikely 5 on the road system in the vicinity of the plant that it would 6 be, really, unnecessary to spend a great deal of training 7 effort on dealing with very massive impediments. 8 But since FEMA choose to insert this type of a 9 free play incident in the exercise, LERO has agreed to do 10 additional training now to cope with that kind of an 11 incident, and I feel that the participants at the exercise, /~ \\/ based on the experience they had there, and the additional 12 13 training on coordination of this type of activity will 14 improve the flow of information. 15 While I think the response that was called for 16 was adequately carried out, FEMA did note that communications 17 were not optimum. 18 I feel this is another aree with really a minimal 19 effort for the fine tuning of the training program that 20 the response can be significantly improved. 21 Q Ms. Goodkind, did you just tell me that it is 22 your understanding that at some point prior to the exercise
17 rn U FEMA had concurred with'LILCO that training for large scale 1 2 traffic impediments was not necessary? JL It is my understanding that the plan was reviewed 3 by FEMA and that there was discussions with LILCO over how 4 much' attention was to be given to the issue of major 5 impediments, and it is also my understanding that LILCO was 6 able to demonstrate because of the good highway system, and 7 the low velocities expected in traffic, and also the 8 9 availability of shoulders along the roadways and so on, that any impediment that would occur would probably not be 10 of real major significance. 11 O 12 Q Is it your understanding that FEMA concurred in 13 this view by LILCO? 14 A Yes. 15 0 What was that understanding based upon? 16 A Discussions with Mr. Brant. 17 Q Mr. Aidikoff? 18 A Mr. Aidikoff. 19 Q Do you believe, Ms. Goodkind, from your 20 discussions with Mr. Aidikoff that LILCO considers the 21 nature of the impediments required to be simulated during 22 the exercise to have been unfair? O
18 s_) . I don't know that -- I can't characterize h'is 1 A 2 feeling of it. We'didn't discuss how he personally' felt 3 -about it. 4 Q You didn't draw any conclusions from discussions 5 you had with him in that regard? 6 A 'As far as being fair or unfair, I don't know what 7 his conclusions are. 8 Q What about realistic or unrealistic? 9 A Well, it seems clear to me that there was -- there i 4 10 were a number of features of that incident that became it unrealistic ~ partly due through some errors. -Some of those 12 errors on the part of FEMA. I 13 I think a large part of the difficulty that was 14 experienced in simulating the removal of the irpediments ; were 15 due to the simulation itself.- That the difficulties would 16 not have been experienced, or at least not to the degree 17 that occurred had it been a real event instead of a l 18 simulation. 19 Q Because, for ' example, LERO personnel in the field 20 couldn't actually see the accident to report it? 21 A Yes, for one thing. Also, where the initial 22 message was inserted was somewhat unrealistic, and resulted O t 9 ~
1 19 in the consumption of a fair amount of time while road 1 2 crews attempted to verify the information which is the way ~ 3 the information flow certainly would come from the field. 4 If there were an accident, the route spotter or traffic 5 control people would be the first ones to note such an 6 incident. 7 Q Do you believe that during the exercise it would 8 have been better if FEMA would have input simulated traffic 9 impediments in the field rather than at the EOC? 10 A I think that might have been a better choice. 11 As it happened, when some other things got combined with 12 the simulation, the FEMA evaluator being in a different 13 location than what people -understood he was going to be in, 14 there were a combination of things during the exercise that 15 made this a rather difficult-demonstration. 3 16 So, even if the message ' had ~been inserted elsewhere 17 there were still other factors that contributed to confusion. 18 Q Are you aware, Ms. Goodkind, the fact that since 19 the exercise on February 13th there have been training 20 drills held by LERO? J 21 A I have been told that is the case, yes. I have 22 not looked at the drills or any documentation relating to
4 20L ' O L) I the drills. 2 Q' If you will assume with. me that following the 3 exercise, around June of 1986, there was a full scale 4 training drill of all the LERO personnel called out, in which the' same scenario used at the February 13th exercise ~ 5 6 was employed again, including the two traffic impediments, f 7 and the same -kinds of problems-occurred again with respect. 8 to LERO performance, would you draw any ~ conclusions from 9 that? 10 A Well, one of the things I am aware of was that i 11 af ter the exercise, LERO committed to make.some' changes. 12 For instance, preparing badges with written instructions for bus drivers so that they wouldn't get confused over when 13 14 they were supposed to report in doses, or what instrumen-15 tation they were supposed to use. Things of that nature. It was my understanding that by June not all of i 16 f 17 these things had been accomplished, materials available, 18 and changes in procedures prepared. I 19 I know that LERO is on a quarterly drill schedule, l t and that the drill may likely have been just one of their 20 21 previously scheduled drills. It may have not been timed 22 in a way to test resolution of all the items that were
21 U 1 brought up in the exercise. 2 O Well, I don't understand what difference it makes 3 that LERO is on a quarterly drill program. How does that 4 impact the question, and the question is: Assume after the 5 exercise there was a full scale training drill. LILCO 6 employed the same scenario used at the February 13th 7 exercise, including the same two traf fic impediments, and 8 the same kind of problems happened again. 9 I have heard a lot of excuses that I think have 10 been offered to you about why LERO performed the way it 11 performed on the day of the exercise. What conclusions, if (~') 12 any, would you draw after the exercise, using the same 13 kind of scenario, the same performance results occurred 14 again? 15 A We ll, I guess I just have to reiterate that the 16 lessons learned from the exercise were that there were 17 some changes needed in procedures and equipment, and I 18 think in order to assume that everything would flow better 19 that the same mistakes wouldn't be made, you would want to 20 have the opportunity to make sure those changes had been 21 made, procedures had been written, that the equipment had 22 been obtained. ("h V l
22 If LERO.had not had the opportunity to complete 1 2 the fixes that they had designed to resolve the issues, then I don ' t know that a retest, given the same physical set of 3 circumstances, would show anything very much different. 4 Q Do you think that a fix that essentially consists 5 of a badge with the instructions on the back to read your 6 7 dosimeter would have some impact on how LERO personnel 8 performed to simulate a traffic impediment? 9 A Well, we are talking about two different things. 10 The badges, I am referring to bus drivers, where FEMA, 'I believe, found that LERO bus drivers functioned very well, it . T (~/ and were very well trained, and were very well informed 12 about their duties and responsibilities, but they noted 13 some cases where emergency workers didn't call in doses 14 s l' at proper times, or didn't know the proper dosimeter to use. 15 I think even though these are rather minor 16 issues not connected with their major role in a major g7 18 function, they are, the things that were cited in the exercise 19 and in order to keep those findings from reoccurring in a subsequent drill, I feel that something like the' badges that 20 were developed would be very helpful. 21 22 0 Is it your understanding that FEMA determined (:)
23 N U-that the performance of the LERO bus. drivers being evaluated 1 was a very good performance.- Is that what you told me? 2 A Yes. 3 Q Are you aware of the f act that FEMA evaluated 4 eight general bus drivers? 5 A I don't recall the exact number. 6 Q You have read the FEMA Report, though? 7 A Yes, I have. 8 g Q Do you recall that of the bus drivers evaluated, three or four were found to do such things as go to the 10 wrong transfer points, get lost on their routes, things 11 of that nature? 12 A I am aware of the errors that occurred. I know 13 that there were bus drivers dispatched from three staging 14 and it is my impression that the drivers at two of
- areas, 15 the staging areas stood very well, and that there were some 16 problems with drivers from, I think it is the Patchogue 17 Staging Area.
18 I am also aware that LERO fielded a great number 19 of bus drivers for the exercise. Certainly many, many times 20 the number of bus drivers that I have seen in any other 21 22 exercise. And that FEMA was given an opportunity to select O
24-1 among this large group of people. 2 Well, that is correct. And of ~ the bus personnel 3 that were fielded by. LERO, FEMA selected eight, and of those eight, three or four failed to perform adequately. Isn't 4 that what the FEMA Report says? 5 6 I didn't see the words that they failed to A 7 perform adequately. There were some mistakes made by some 1 of them. ^Whether you can say it was an inadequate 8 g performan ce, I am not aware of that~ characterization. Q Well, assume with me that my numbers are correct, 10 11 and that of the eight that FEMA I suppose randomly selected to evaluate, three-or four were concluded to have failed to 12 33 perform adequately. 34 Is it your testimony that that still, nevertheless, w uld not be a significant training problem? 15 j. A Well, I guess we are still kind of differing on 16 17 characterization of failed to perform adequately. Q Well, let me-give you an example so we don't miss 18 19 the point here betweed each other. FEMA when they select a bus driver to evaluate, typically actually gets on the bus 20 21 and rides and observes the driver. Is that your understanding? i 22 A Yes. They will observe a certain number of O-i 4 ) m. vw-- --n ,,~n- --.we ,v, ,,-..-.,,-,nwan-w.-- .-m--,m-+e .-,.,,-a-, _v,----ny,- m,n-nm,-,--rn,,, y ,e..w
25' s '. 1 drivers. 2 Q Okay. So for the purpose of my question, 3 assume that the FEMA evaluator got on a bus and observed the 4 driver drive his route, but unbeknownst. to FEMA, the. driver 5 drove the wrong route, or the driver got lost, or the driver 6 went to the wrong place. 7 That is my definition of, ' failed to perform 8 adequately. ' Now, if that in fact was the case during 9 the exercise, and three or four of the eight observed to bus drivers performed in that way, would that tell you 11 anything about the quality or adequacy of the LERO training 12 program? + 13 A Well, you are citing a case where a driver 14 got lost, and I don't know that I saw that during the j 15 exercise. i 16 Q Assume the basis of my question. It is a 17 hypothetical. 18 A Well, the function the bus drivers are trying to j 19 do is assist in evacuation of people, and I feel the bus 20 drivers are not isolated, and ' that bus drivers can make 21 mistakes, and the function can still be carried out. 22 So, if you see that a bus driver got lost, would ( I i
26 / i V 1 you conclude that all the bus drivers failed -- even if 2 all -- if you had eight bus drivers, and eight bus drivers got lost, was the function a failure? If you had people 3 at the transfer points who could use independent judgment 4 and could redirect the drivers, so the function still got 5 carried out efficiently, then your system is not a failure. g The way I have to look at it, the bus drivers are 7 part of the system. 8 Q Tell me, Ms. Goodkind, what would it take for you 9 to draw the conclusion with respect to LERO bus drivers, 10 there had not been adequate training? If eight out of the 11 (n, \\_) eight observed getting lost wouldn't tell you something 12 about their training, tell me what it would take in your 13 mind? If they can walk onto their bus, is that good enough? 14 A Well, in theory I presume that the operation 15 could be carried out with bus drivers who had no training. 16 You are asking for a hypothetical situation. g7 There are so many different cases. Bus driver 18 equipped with a radio could, perhaps, fill the function with 19 no training whatsoever. It is difficult for me to set the 20 parameters that would define a failure of a training 21 22 program. j \\
i 27 g-v 1 Q Okay. Here we have Shoreham buses without 2 radios. So, take that one out of your answer. Is your .3 testimony. that under the LILCO plan, ~or the LILCO system 4 as you - unders tand it, bus drivers could perform,without any 5 training? 6 A Well, you know, I have seen several evacuations 7 that were successfully condun ted with no plan, let alone no y 8 training. 1-B 9 .Q I am not sure you answered my question, but is. 10 that your answer? A I am looking at the overall function, and the 11 12 overall function beihg carried out, and to me that is a 13 definition of whether training is adequate. 14 Q And at this time have you determined in your own mind whether under the LILCO Plan the overall function can i 15 be carried out? 16 17 A Yes, I believe it can be carried out. 18 Q And what is that. opinion based upon? 19 A Well, I believe that FEMA gave a positive evaluation of the performance of the bus drivers. They 20 stated that LERO bus drivers were well trained. 21 22 Q I think we are back to where we started forty-
28 (+ k' 1 five minutes ago. 2 I don't think FEMA stated that, Ms. Goodkind, 3 but I. am not here to argue with you about what FEMA said 4 and didn't say. 5 Let's go off the record for just a second, Joe. 6 (Off the record discussion ensues.) 7 BY MR. MILLER: (Con tinuing) 8 Q Ms. Goodkind, we started with your resume, and 9 I got away from your resume, and I now want to go back to 10 it. If you will look at it for me, please. 11 MR. CUMMING: Do you have an extra copy of it 12 by chance? 13 (Mr. Miller hands Mr. Cumming a copy of Ms. 14 Goodkind's resume.) 15 BY MR. MILLER: (Continuing) 16 Q Do you consider yourself a health physicist? 17 A Well, I have a Master's Degree in Health 18 Physics. I consider myself more a safety specialist. 19 Q A safety specialist? 20 A Yes. 21 Q Where were you employed prior to going to Impell? 22 A I was employed with a consulting company called A
29 1 s -s) i ETA Engineering. - 2 0 Is that located in Chicago? A It.is located in Westmont, Illinois. It is a 3 4 Western ' suburb of Chicago. 5 0 And what duties did you have while you were at 6 ETA Engineering? 7 A I was involved in emergency planning for 3 8 Commonwealth Edison, particularly at the Quad Cities station. I. Was the controller during the 19 85 exercise 9 while I was at ETA. I also provided some assistance on the 10 Prompt alerting notification system for Quad Cities Station. 11 I I did a number of other functions related to 12 health and safety, including safety plans for chemical 13 14 facilities. Q Ilow long were you at ETA Engineering? 15 A I was there about three years? 16 i g7 Q And where were you prior to that; prior to that 18 time? I 19 A I worked for a consulting company called ESCOR, and while I was there I had a number of assignments. One ~ 20 of my assignments was to assist Argonne National Laboratories 21 as observer in FEMA evaluated exercises. 22 O 1
30 / 1 \\_J' 1 Q Ms. Goodkind, your various jobs with various 2 consulting firms, does this resume reflect, at least 3 generally speaking, the jobs that you have held? In other 4 words, this resume is not confined to just your present job 5 at Impell, is it? 6 A No, it is not. 7 Q So, this is a fair characterization of your various 8 jobs and various consulting activities during your career? 9 A Yes. There are some other areas that are not 10 Particularly emphasized on this resume. I have experience 11 in the general field of environmental regulation.
- Also, x/
areas such as noise control. 12 13 Q When was the last time you consulted, or acted 14 as a consultant for Argonne National Laboratories? 15 A It was during 19 86. I 16 Q Was it with respect to a nuclear facility? 17 A Yes. 1 l l 18 0 Which facility was that? I 19 A There were two facilities. Vogel plant, and the l 20 Oconee plant in South Carolina. 21 Q Do you still render consulting services to 22 Argonne National Laboratories? I e^s l l
s 31 .(,)- A I.am not at the current time. 1 2 0 Are you aware-of the fact that during the Shoreham exercise, Argonne National Laboratories worked with FEMA - 3 4 to help evaluate the exercise. In fact, essentially prepared the Post Exercise-Assessment Report? 5 A I know that individuals from Argonne acted as - 6 evaluators. I am not aware of what their role was in 7 a the Report preparation. 9 Q Have you thought about whether there was any conflict between your retention on behalf of LILCO, and to your consulting work you have performed for Argonne 11 National Laboratories? 12 A Well, as I noted earlier, I am not under contract 13 14 to LILCO. 0 You are under contract to Hunton & Williams, which 15 is the law firm for LILCO. 16 A I don't believe there is any conflict of interest, 17 given the issues which I am going to be addressing. l gg ig Q Is that a matter you have discussed with anyone? A No. I have been asked some questions by Ms. 20 l-Monaghan about what my involvement was in certain aspects h 21 22 of training development. (
---. -.~ n, 32 q.Q t Q. Questions in the context of possible conflict of-- t 2 interes t? 3 A I think to some extent related to that. Questions 4 of whether I, for instance, prepared training materials for. 5 use at Shoreham, which I did not. 6 Q APProximately what time frame during 1986 ' did you - last render services to Argonne National Laboratories? Late 7 i 8 ' 86 or early ' 86? g A I gave them assis tance.with.the exercises ~ Ehat' 10 I mentioned at Oconee and Vogel, which wer6 bothIin the 11 early spring. My recollection would be maybe March of ' 86. I could confirm the date. 12 13 Q What were the nature of the services you were I 14 rendering to Argonne at that time? A I acted as FEMA evaluator under contract to [ 15 16 Argonne. 17 Q While you are under contract to Hunton & Williams, 18 do you believe that you could render consulting services to 19 Argonne National Laboratories? i A Well, I don't believe that I would be in a l 20 21 Position to accept any consulting work from Argonne i 22 Laboratories, but I haven' t really thought about it. There i 4 - - ~
1 33 O. 1 is no anticipated contracting between me and Argonne 1-2 Laboratories.- 3 Q Do you consider yourself a planner? i 4 A Yes. 5 Q Do you consider yourself a. trainer? 4 6 A Yes. 7 Q If you had to weigh one against the other and ~ 8 say which-you think you'are more expert-at, which would i't f i 9 be? A planner or a trainer? 10 A Well, I don't know. 'It is rather difficult to 11 say. I have done training on a number of~ occasions for 12 different audiences, and I have also done quite a bit of 13 planning activity, so it is difficult for me to weigh one 4 14 or the other. 15 Q About equal in your mind? I am kind of curious. 16 You head up a section on this resume: Radiological. 17 Emergency Planning Experience. And it goes on in most of 18 this resume. But it is not radiological emergency training 19 experience. i i 20 A Well, training is usually short te rm and 21 intensive, and I have' only -- I have cited some development 22 of training materials, but I haven't mentioned on here i t i
1 y 7-34 ~s ~ s,) I' training sessions that I conducted, say, for industry 2 groups or for county officials, orfmedical drills. I haven't J 3 ' included on. my. resume a tabualtion of training activities. 4 But, for instance, I have conducted training -- -- 3 [ 5 . I think I' did cite in here' for the U. S. ' Department of-6 Energy to help train their evaluators, but my, current 7 assignment with Commonwealth Edison is primarily related to ~ 3 8 planning. 9 Q Are you a certified trainer?- 10 A-I am a certified safety professional. I don't 11 know what the category of certified trainer would be. A s. ( 12 certified safety professional is the person who is knowledge-13 able in health and safety issues, and a large part of what: 14 safety professionals do includes teaching training education.. L 15 Q But you are not a certified training instructor,' 16 is that correct? i i j 17 A No. I am not even aware there is such a category. s 18 0 Under the category Radiological Emergency Planning Experience on your resume, Ms. Goodkind, you have an 19 i 20 indication that -- in fact, it says you have radio 3ogical emergency planning experience that includes - and you have I' 21 3 22 three bullets. The first one you list is that you have (:) i i
t 35 tQ,) I been evaluator -- exercise evaluation as a FEMA observer, t 2 And at the bottom of the page, you state that i 3 you participated in ten exercises as an evaluator. 4 Do you draw a distinction between observer and 5 evaluator? 6 A I am sorry, distinction between -- 7 Q -- observer on FEMA'.s behalf, and evaluator? 8 A No. I do draw a distinction between being an 9 evaluator or a controller. 10 Q I understand that distinction. Between observer 11 and evaluator? I A No, I am not making any distinction between 12 13 evaluator and observer. 14 Q Now, the next bullet says you have developed 15 emergency plan procedures and training. Could you tell me 16 what training you have developed that would relate to the 17 training of what I would characterize as emergency service 18 personnel. Do you know what I mean by the term, ' emergency 19 service personnel?' 20 A Yes, I think so. Well, there are a couple of 21 different kind of things. Impell Corporation has a number 22 of different types of training documents that they have tV;
36 O 1 Prepared as a kind of standard training modules. 2 .One of the things I have done is select among 3 available material-to design a training program appropriate 4 for, say', an ambulance company that' might be expected to ~ 5 respond to an emergency. 6 And then as part of the development of ' training, 7 I might do something like develop a scenario of how a person 8 would become inj ured, and become contaminated and I would 9 set up a training session that might include audio-visual i 10 material, hands-on experience with equipmen't, and practice 11 drills scenarios, as I mentioned for -ambulance companies or f 'A 12 for fire department. 13 I have also done training on what is known as 14 table top drills. I did one rather recently on recovery 15 and reentry with county officials. 16 Q With respect to emergency services personnel, 17 typically that would be your police and your fire departments, 18 would you agree? 19 A Yes. 20 0 What I am interested in is what training have 21 you specifically developed, if any, with respect to emergency 22 services personnel. You mentioned an ambulance company and
. 3 7' . /'\\ ,.V 1 fire departments. Is there anything else? 2 A Well, some of the training has been in EOC 3 situation, where you would have a sheriff participating 4 in ' table top training. 5 One of the things that Impell does is tx) help ~ 6 people understand what their. role' is in an exercise or in 7 an emergency. Impell provides to an EOC, such as a county I 8 EOC, what we call an EOC work book, and one woulddbe given 9 tx) the police department. One would be givenito the local 10 education administi ator. One would be given to the fire 11 chief, and what I would be doing -- what I am doing for 12 Commonwealth' Edison is extracting from Ehe overall plan 4 13 and putting together materials that are specific to each 4 14 individual function, and then we will be offering training i 15 -- providing training to each of the responsible individuals 16 who would report to the EOC so that dhey are familiar with 17 their portion of operating procedure. 18 We have a staff of trainers at Impell. Some of 19 them are ex-military. Some are former sheriffs. Depending l 20 on their special expertise. I might go, or one of our other 21 people, if we have someone who is with the fire department 22 or the sheriff's department, which we do. These people might () s. .-n. -., _,. - - - - -.,,,, -,,,,,,,.,
N 38 i o be assigned. i i 2 Q Is it fair to say that typically. in a training . context you prepared the materials for the training program, 3 rather.than actua1' instructing the people that are being 4 trained? 5 A ot necessarily. Sometimes it is one way, i-6 sometimes it is the other. Sometimes it is both. There 7 is some use of standard material prepared by our company. 8 There is some use of materials - diat might be prepared. by 9 other organizations; atomic industrial forum, or any other 10 organization. 11 A !. (-) And parts of training are just about always 12 i produced for the application. 13 MR. CUMMING: Could we go off the record for g4 a second. 15 (Of f-the-re cord. ) 16 BY MR. MILLER: (Continuing) g7 Q Ms. Goodkind, let me back up for a minute to 18 what you said about your experience as a trainer. Have 19 y u ever developed from scratch a training program for 20 emergency services personnel? 21 A I wouldn' t say from scratch, because certainly 22 0 9 e -,m ,r w,, ,---,--4 -,.&,my,.y.--... .-my -,y -,m. -,w.-, ,--,--m,,-.r-www,&,
nl v. 39 O-i when you are working with emergency services people in any 2 particular' location, there is an emergency plan, f and that 3 emergency plan -generally has a lot:of written procedures, mui 4 4 the training uses those procedures. 5 So, I haven't been involved in a situation where there are no training materials that have been prepared and 6 7 used with emergency workers. 3 I have prepared some original training-materials g for people in Government. For instance, the Department of. 10 Energy, but that is not the question you asked. - It wasn ' t 11 emergency workers, such as policemen, fire. The training. I have been involved in for those individuals has always 12 made use of either plans and procedures that were well 13 14 developed, or it has made use of some standard training materials, maybe on the nature of radiation, something like 15 that. f-16 17 So, I would say in most cases I have prepared 18 some aspect that is specific to this application, like 19 perhaps a drill, the format of a drill. If I were to work with an ambulance team, I would write up for them what they 20 21 were going to simulate. 22 Q With respect to your experience in developing l l i
40 , "x training materials, is it fair to say that you typically i 2 take some base document or documents, and either use those 3 documents, or modify those documents, to be used in training? 4 A I would say that is typical. 5 -Q And I assume that a number of times those are base documen ts that are already at an organization, like at Impell? 6 7 A Either at Impell, or at the utility, or at the 8 county, or at th e s tate. 9 Q Now, is it correct that you have actually performed 10 as a training instructor with respect to emergency services 11 personnel? O \\"l A I have assisted with a team of other people with 12 13 emergency personnel, yes. 14 Q Now, in the case where you assisted, what emergency personnel were involved in that training? 15 A Ambulance personnel and fire department. 16 i 17 Q And what was your role with respect to assistance 18 you rendered in that training program? 19 A It was assisting them with learning about their instrumentation, how to charge dosimeters, how to read 20 21 them, preparing many scenarios of events. I helped conduct 22 drills. I helped train participants, such as fire chief on /3 (/ l l I L
4 ~ 41 how -to operate a decontamination center, where my role was I 2 - to go with them and help them understand.the layout of the 3 facility which Impell had helped develop. 4 How different areas would be used, and I assisted 5 them in that training. That effort was led by the fire 6 department. There was cooperation by national guard, the 7 red cross. These are different instances Unat-involved 8 different things at different times. 9 0 With respect to your experience as a trainer, where 10 you actually provided instruction as a member of some team, 11 has your experience been limited to matters regarding 12 dosimetry use and matters regarding radiological monitoring 13 and decontamination? 14 A No. 15 0 What other areas have you actually trained 16 personnel, emergency services personnel? 17 A I have trained, as I mentioned, on recovery and 18 re -entry. Now, it may not meet your definitions precisely 19 of emergency workers, although emergency workers are 20 involved in that. Say, the police. In recovery and 21 re-entry, police have a role in taking down the barriers and 22 allowing reaccess to an area. l i
+ 42 es. In training for decontamination,.there are'a. 1 number of things involved. Registering people, giving 2 people instructions on where to -- be directed from the 3 reception center. It is the whole flow of operation 4 facility. Training on how to provide people with emergency 5 medical assistance. 6 Also, done training of school personnel on 7 - khouJ protective action for children. Again, I don't^if that If) 8 really meets your defintion of emergency workers. It is 9 part of the training that I have done. 10 Q Have you ever been involved in evaluating the 11 } perf rmance of emergency services personnel? 12 A You are saying as a FEMA evaluator? 13 Q No; in any context? 14 A Well, I. have been a controller on two occasions, 15 i and on those occasions I was evaluating a number of functions 16 out of the EOC such as traffic and access control. 17 We have evaluated the performance of ambulance 18 19 crews in drills. Were they able to accomplish their 1 tasks in an efficient way? 20 21 Q Okay. Have you personally evaluated the 22 performance of ambulance crews? i 1 4 .w ,---7 --=-W- +- + - - * * - - - - - - + - r7+ w, -m-t- w-" '----'v- ~ ~ + ' --7 r e -r e m r,
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I 43 ~ A I have done it in a somewhat informal way. 1 2 We provide the teaching and then we ' observe them go through 3 a practice, and then we debrief them on how they did. That 4 would be a1 typical evening training program. 5 Q _ From your review of.various documents you have 6 seen to date, are you familiar with the concepts of various 7 LERO personnel, including the following: traffic guides, 8' road crews, bus drivers, route spotters, route alert 9 drivers? 10 A Yes, I think I am familiar with their functions. 11 Q Now, have you ever provided training with respect 12 to any personnel whose job would be analogous to any of the' 13 LERO jobs which I just listed? 14' A' I provided training to sheriff, chiefs in the 15 sheriff department, and fire chief. I think some of those 16 tasks.would be analogous. 17 Q Has the training that you have provided been 18 limited to more management functions, though, than field 19 functions? 20 A No, I don't think so. I am not sure exactly what 21 you mean, but if you are asking have I gone to an ambulance 22 company and actually physically gone over with them the O i
44 ,,b) ~ protection of ambulance equipment from contamination, have 1 2 I done hands-on operation of instrumentation with them, have 3 I physically gone to decontamination centers, yes. I think 4 the answer to that is, yes. 5 Q No. With respect to the sheriffs and the fire chiefs that you mentioned that you have trained, have those 6 7 people been performing in more of a management role:than dn 8 a field hands-on role? 9 A They would typically be the people responsible lo for directing these people in the field primarily. I have 11 done training where a large number of fire fighters are 12 present, with not all management staff. 13 Q Was that dosimetry training? 14 A It is -- dosimetry training is included in it. It is also to familiarize them with the fact that an 15 16 emergency plan exists, and how it af fects them, and what 17 their role is in an emergency response. What their primary 18 duties are. How to protect themselves while they are 19 providing assis tance to others. It is teaching them how they might receive notice 20 21 that they are needed at a particular time. Who would be 22 responsible for authorizing them to provide this response. (v~)
45 -A It is providing them with maps and information on, say, i the medical teams, which hospitals have agreed to provide 2 support. Where they should go once they get to the hospital. 3 4 Whether there is a separate area that has been set up for 5 someone potentially contaminated. 6 Q Towards the bottom of the first page, there is 7 a paragraph that describes some of your background. It 8 says that your training experience have included exercise 9 evaluation, control, and training in the following areas; 10 and you have a list of the areas. 11 Have you trained personnel in all those areas 12 listed after the colon? 13 A Well, I have trained people in county emergency 14 operation center functions. I have trained people for field 15 team activities, primarily field team here -- the training 16 would be more training people who need to monitor their 17 exposures in the field. Where I have been involved 18 generally, there are knowledgeable and trained field 19 people doing radiological assessment. I haven' t been 20 involved in additional training for that type of staff. 21 Training for radiological dose assessment, I 22 have assisted people with practicing that, and I think n
46 1 practice is a part of training, so I think you can say I 2 have done. training in that area. 3 Prompt alerting and notification, I have assisted 4 somewhat on providing information to media and stations, so 5 it is not so much training as public information function. 6 Early dismissal of school students, yes, I would say I have 7 done training in that_ area._ I have met with individual 8 school principals and school superintendents,. and have tried 9 to provide them information about the emergency plan at a 10 nuclear station, what duties might be expected of them. 11 What provisions have been made for the protection of the 12 school children. These types of activities. 13 I have also provided representation on behalf of 14 Commonwealth Edison to respond to questions regarding 15 emergency planning. Decontamination and relocation 16 center operation, yes, I have provided training. Medical 17 drills, yes; and recover and re-entry, yes, I have provided 18 training in those areas. 19 Q Ms. Goodkind, do you draw a distinction between 20 educating a person and training a person? j 21 A Well, I by the nature of your question -- 22 I am trying to answer your question as honestly as possible, ' O L-
47 gs ( and as clearly as possible, and when you talk about i 2 training a fire department, I see some distinction between 3 that and educating school principals. Training, I think of 4 more teaching them how to do hands-on activities. How to 5 calibrate dosimeters. How to put up protective materials 6 against contamination. It is training maybe as repetitive 7 actions. 8 Educating people, working with the superintendents, 9 just to be sure they understand the plans and procedures that 10 are in place. That is really the distinction I am drawing 11 between training and educating. /~'% \\- 12 Q So, for example when you discuss what you have done la with respect to the early dismissal of school students, and 14 your meetings with superintendents or principals of schools, 15 is that an educational function or a training function? 16 A I would call that mainly an educational function. 17 At times, it takes a training aspect. For instance, as part 18 of the early dismissal program, we met with the PTA and the 19 Lions Club, and members of the public in a general meeting, 20 and that may be rather difficult to define whether that 21 was educational or training. I would treat them as education, 22 but it did involve teaching something about what happens (O _/
1 - 48 1 .during an emer~gency. What organizations are required to 2 respond, and what plans have been developed to coordinate 3 a response. 4 And some general information about the nature. of radioactivity, and what protective actions -might be 5 6 carried out. It is kind of a combination, I guess, of l 7 training and education, 8 Q You are familiar with ' the fact that under the 9 LILCO Plan there. is no participation by the State or Local to Gove rnments, including Suffolk County, is that correct? 11 A Yes, I am aware of that. 12 0 I assume that in the context of other nuclear facilities that you have been involved in educating and 13 training personnel, the personnel primarily relied upon to i 14 provide offsite emergency response to protect the public health 15 and safety, were personnel who are already knowledgeable and l 16 3 have been trained in performing public health and safety 17 1 18 functions, is that correct? 19 A Maybe some -- it is a sweeping statement. If I 20 could have the opportunity to rephrase it. The other locations where I have been controller or evaluator or developed plans, 21 i 22 the state and counties have participated to a greater or lesser O i i .r,.,-.,._,-__m.,,-.-.~m -...,,,,,,,,-,,,_w.,,,.,,._..---,, m,%. v..,,,,, ,,.e.,,., _ _,. _ -, _, - -., - -mw -_.e.-s,,. .r-,_%,., .r.,,_,.-e
49 gV 1 extent in providing support functions. 2 O Wel'lj what I am curious about is, for example, 3 at other plants you have been associated with, if traffic 4 functions need to be planned for and trained for, I assume 5 generally police would be relied upon to perform those 6 functions, is that correct? 7 A Yes, I would say so. Police or the Sheriff, 8 yes. 9 Q And under the LILCO Plan, LILCO personnel would to be relied upon to perform those functions? 11 A My understanding of the way the training has been n (ks) 12 done for traffic control point workers, they have been 13 trained on how to provide assistance. It is not exactly on 14 how to assume the functions that a policeman or a sheriff 15 would do, but it is to provide assistance that could make 16 the movement of traf fic easier, and I also understand that j 17 the training has addressed how the traffic control workers 18 who would interface with police or sheriff representative, 19 if such a person were there to offer assistance. 20 0 What is your understanding as to how a LILCO 21 traffic guide would perform his or her function in the 22 event of an actual emergency? What would they do? O \\_J l i e p + -. -
n 50 D' V 1 A It is my understanding they would have available 2 things to use such'as cones, to help with 'the flow of 3 traffic. That they would be available to provide information 4 to people on what routes might be best for them to take. 5 That they would watch for any impediments that 6 might occur.. And if police of ficer, for instance, did decide 7 to respond, then the traffic controller would be informed and 8 educated on what the plan would be in those areas, and would 9 be available to assist the officer. 10 0 Is it your understanding that under the LILCO 11 Plan, traffic guides would not actually attempt to direct O-. 12 traffic? 13 A Well, I think they would direct traffic and 14 assist the flow of traffic.- They would not be doing functions 15 like giving people tickets, or they don't have any enforcement 16 status. So they would be there only to advise and assist. 17 Q But they would stand at intersections and facilitate 18 the movement of traffic by directing the traffic. You 19 unders tand that is the case? 20 A That is my understanding. 21 0 Do you have any understanding, Ms. Goodkind, as 22 to the people within LILCO who have been selected to perform O
d 6 f 51 i this function of traffic guide? 2 A I understand.that they are regular company ' employees not specifically connected with the Shoreham plant, 3 and that they would probably be people like line crews. 4 5 0 Meter readers, whatever? 6 A Something like that. My understanding that 7 people selected, for instance, to be ' bus drivers, are all qualified for that type of vehicle and have experience with 8 9 other types of heavy equipment. l 10 0 Focus with me on traffic guides for the moment. Assume that the meter readers of LILCO primarily comprised 11 12 the LILCO traffic guides. Is it your opinion that through training you can teach someone, some group of people, who 13 14 have no experience in a function such as directing traf fic, to perform adequately in the event of a radiological 15 i 16 emergency that function? i j 17 A Yes, I think so. l i 18 0 Now, is that opinion based on any experience of I L 19 any kind, or is that your jud7 ment, or what is the basis L 20 for that? 21 A I have that opinion because the task is not very 22 difficult. I think you can train someone reliably to observe O
t-s '52-
- 1 whether there is any obstruction in the area.
1 Fr 2 Since I understand that' these people have radios, 3 I think you can train them to perform an important-function, they are only just to watch for problems along the 4 even were 3 road. I think that could be valuable. 6 And I also -feel that their function is not 7 necessarily essential to an evacuation. We have a lot of I i a evidence that evacuations take place rather routinely without ~ 9 something like a traf fic guide. t to O That is a different issue. We are focusing here 11 on traffic guides, and the ability to train them under the 12 LILCO Plan. ja Now, the same with the traffic guides. Is it your l 14 testimony that under the LILCO Plan the task assigned to 15 traffic guides is an easy task to perform? Is that what 4 1 i 16 you said? 17 A Yeah, I don't think it is a complex task. l 18 Q So standing in an intersection in the event of 19 a radiological emergency, with the traffic that would be 1 20 expected, and the kinds of people you may have to deal with, 1 1 21 to you would be the performance of a relatively easy task? 22 A Well, I don't know that easy and complex are 1 1 l. I
J 53 ~ t exactly opposites. 2 I don't think-it is a complex task. There may 4 be stress involved with it because of the accident 1 conditions 3 4 and the traffic congestion and so on, so it may be that -it. is not a complex tast. It may not be an easy task-to carry'out, 5 if you see the distinction that I am making. In terms of 6 j ' 7 training, I think it lis relatively ' easy to ' train someone s on what it is they need to do. g Q Ms. ' Goodkind, there are no publications listed i in on your resume. Have you published any. publications? A Yes, I have. gg 0 If it is not an extensive list, you can just tell 12 13 me. If it is an extensive list, then maybe'you can pr' ovide I it to me later. t. .A I was just last month listed in a publication from i 15 16 the National Safety Council, and I was the author of a 17 chapter in a journal on hazardous waste ~ management, and 18 addresses how industry should manage hazardous waste. It to is a somewhat related issue in that contingency plans are required and safe procedure plans. Emergency preparedness. 20 I I am also the author of a paper that has been 21 22 submitted as being considered for the meeting of the r
4 I m 54 (vN 1 International Atomic Energy symposium.that-will be held in 2 Chicago' this fall, and the paper will be on' the topic of 3 protection of school children, and it isi co-authored by 4 the manager of governmental affairs at Commonwealth Edison 5 Company. One of their emergency planners. 6 I don't know that it has been accepted for 7 publication, but I anticipate that it will be. f-8 I am the author of an article that was presented 9 at the Health Physics Society topical symposium on offsite 10 radiation monitoring. It is a compilation of data ' that NtAAJdLD MCC 11 were collected at the Or-d "it'r Nuclear Power Station, 12 in Wisconsin, and it analyzed several years of monitoring 4 i 13 data in the environment. i 14 I cited one training module that I prepared 4 15 through Argonne National Laboratories, and I believe this 16 is a part of their training material they had prepared under 17 contract to the U. S. Department of Energy. 18 I was contributor of a report on low level waste. I 19 options for the Illinois Atomic Energy Commission. This was l t 20 a governmental appointment to an advisory staff. l l 21 That is all I can recall. i 22 Q Can you tell me the thesis of the paper that O 1
55 g ] i had been submitted with respect to the protection of school 2 children? 3 A Yes. At the Quad Cities Nuclear Station, follow-4 ing the exercise there in August of 1986, the FEMA Region VII 5 expressed some concern over the plan for protection of 6 school children, and particularly with regard to what might 7 happen during dismissal of school children, and whether there a were adequate plans and procedures to make sure that students 9 wouldn' t be released into an area that would be more 10 hazardous. 11 So, I worked with Commonwealth Edison planners O(-) and with county officials, and what they call in that area, 12 13 area education administrators. 14 Impell developed what we call a standard operating 15 procedure that gave four alternatives that could be selected 16 for protection of school children. 17 We drafted this SOP. I reviewed it with the 18 people I just mentioned, and it was incorporated into the 19 plan. There were several issues along with that that needed 20 to be considered, so that is the subject of the paper. 21 O What were the four alternatives? 22 A The four alternatives are closing -- keeping n s-
56 (3 \\'"/ I schools closed, and not opening them for the school day. 2 The other alternative is to shelter within the a school. The third alternative is to do what we call a 4 partial dismissal. If you can select among your students 5 those who live, say, outside of the EPZ, you may choose to 6 keep some of the students at the school, and send some 7 children home. That is a partial dismissal. 8 Or, you may do a full relocation of students, 9 where you would use school bus or some other transportation to means and take all of the children to another location, such l 11 as a reception center. (~% 12 Q I gather from your comment about having been an 13 expert witness on environmental issues in the states of 14 Illinois and Kentucky, that you have testified before? 15 A Yes, I have. 16 Q Have you ever testified before the NRC? 17 A No. 18 Q Is the testimony that you have rendered in the l 19 past been in a court? 20 A It has been before, for instance, the Illinois 21 Pollution Control Board on numerous occasions, and the other 22 was Kentucky similar-type administrative body in the State of I /~T l \\-)
57 ( ) 1 Kentucky agency that would issue air permits. - This was 2 related to development of a coal-fired power plant. 3 Q Have you ever testified' in any matters relating 4 to radiological emergencies preparedness, training prepared-5 ness? 6 A No. 7 Q Ms. Goodkind, do you understand the term, ' performance objective? ' o 9 A I don't know specifically what context that comes 10 out of. I guess in my own employment, for instance, my 11 employer has performed subjectives (sic). ul 12 Q From a training context, does the term, ' pe rfo rman ce 13 objective' mean anything to you? 14 A To me, it would mean that in the development of 15 training programs, you determine what you want the training 16 to accomplish. What people would be able to demonstrate in 17 terms of their performance. 18 Q And in a training context, would you want those 19 objectives established prior to the commencement of the 20 training program? 21 A I would think so, yes. 22 Q Now, does the term, ' performance standard' mean i s>
58 /N ~ 1 anythi'ng to you in a training context? 2 A Not especially, no. 3 Q Have you ever heard.the term, ' perfo rmance 4 standard?' 5 A Yes. 6 Q Would you personally draw a distinction between 7 ' performance standard' and ' performance objective. ' 8 A I don't know in what way performance standard 9 would be applied. I don't know exactly what situation you 10 would be applying it to. 11 Q I am just asking you in a training context -- let s'] k-12 me ask it a different way. Do you believe that the terms 13 ' performance standards ' and ' performance objectives ' are 14 interchangeable terms from a training perspective? 15 A I don't have an opinion on that really. la O Do you believe that in the context of a training 17 program there should be a way to determine whether performance 18 objectives are reached? 19 A I think that would be a good goal. I don't know 20 if it is possible in every instance. Most training is done 21 in very much a real world type of environment. I think that 22 is one advantage thei LERO organization has, where the people O
59 ts l) I they are training are more of a captive audience. 2 A great deal of training that-I have been exposed 3 to is a less control situation, where you are subject to 4 higher turnover in the trainees. You are interfacing with 5 another organization, such as an ambulance company, that 6 may be willing to give you a certain amount of training time, 7 but is not willing to have their people subjected to tests. 8 Q Do you have any understanding as to whether or 9 not the LERO training program has any mechanism for deter-10 mining whether performance objectives are met? 11 A I don't know, other than know that LERO has been O k' running drills, if you want to call them exercises, and 12 13 attempting to evaluate them themselves in a way similar to, 14 say, how FEMA might evaluate it. 15 Q And at this time you have not seen any of that 16 documentation, is that correct? 17 A I have not seen any of the documentation on 18 drills and exercises following the February exercise. 19 Q llave you seen any of that material prior to the 20 February exercise? 21 A I don't believe so. 22 0 When you use the term, ' captive audience,' is O
60 j 1 it your assumption that LERO as an organization has not faced 2 any problems arising from ' turnover of personnel? 3 A It is my understanding,or mycbelief that their 1 l 4 . turnover is probably lower than is experienced when you -are 5 dealing with a wide variety}of offsite ' organizations who 6 provides support. 7 I know at some sites where I have been that 8 whole organizations can be eliminated by executive flat 9 or something of that nature. In Illinois, we have an i to Illinois Atomic Energy Commission that provided some kind 11 of activity, and it was eliminated by legislation, i 12 O Do you have any knowledge at this time as to the 13 attrition rate that had been faced by LERO? ? 14 A I have asked that question of Mr. Aidikoff, and - 13 we discussed it rather generally. It is my understanding that i 16 turnover is relatively small. 17 Q Did he give you a percentage? 18 A I think he did quote a percent. It would be my i i 19 recollection that it would probably be less than five percent 20 a year, i 21 Q Ms. Goodkind, do you consider yourself qualified 22 to evaluate the performance of emergency services personnel? _ _ _ _ _. _ _ _,,, _ _....,, ~ ~, _.. _,. _ _.,.. ~.. _,,, _.. _ _ -,,. _. - _. -,.. _
1 j: J 61 t ~(:) The training performance of ' emergency service personnel,f such t 2 as law enforcement personnel? 1 A Well, any one pe'rson "can' only be in one place at 3 -a time, so'I don't know what you are' asking. Can I look 4 at documentation of what was expected, and how they did, 5 and 'make some opinion of wheSherithey performed well or not? 6 7 Q Well, lets focus on documentation review 8 perspective. Do.you consider yourself qualified to evaluate ~ the performance of emergency services personnel, such as .g a law enforcement personnel? 39 4 MS. MONAGHAN: I am going to object to tlle questior 11 12 as vague. It is unclear to me whether. your question is directed in general, or it is in the contest of emergency 13 t P anning. You can answer the question if you can. l i 14 THE WITNESS: Well, for instance,-with medical 15 drill, it is my feeling that the way we provide training, 16 l a medical team -- say, an ambulance ' team -- their primary g7 function is to provide alleviation of the life threatening i 18 i ig situation, and our training evaluation includes: Are they able to do their primary function? Which addressed that i 20 life threatening situation. 21 L And then we also try to reduce the danger to the 22 I i i ..w.. +-,,., sw-,--am %,w,.--,.mm.,n,,,, .-..w.w_,,..,...m.y~,.,,,,,-,.~.w..p.. y.,-..--3..,... _,,.. ,_ew w w w- -- e
r-3 62 /~s I g, 1 support people by teaching them how they can reduce the s 2 risk to themselves.' ~. 3 So, I think a person evaluating ~what they are 4 doing has to look at two things; you want to make sure that x your training isn't interfering with what' they know naturally 5 6 as their function, and also that they.have gained some 7 confidence of what they would need to do if they were going 8 into a certain area. 9 I think I am familiar with what constitutes a 10 good performance on the part of a medical team. 1 s 11 0 Okay. Now, my question went to emergency services n k-) personnel, such as law enforcement personnel. What is your 12 13 answer to that question? 14 A Well, again I know some of the factors that would 15 be important in trying to assess whether people did a good ob. 16 g7 Do they know the purpose of access control? Do 18 they understand evacuation methodology enough to perform their 19 job. I think based on my knowledge of evacuation procedures, 20 and the role that police or firemen would perform, I think 21 I am aware of the factors that would be relevant to a good 22 perfo rman ce. O
g... _ -{c; 1 163 . (v. c 1 Q So,. do you consider yourself qualified to render .J that sort of evaluation? 3 2 A Yes. 3 ~ { 4 Q Earlier, you mentioned that you had reviewed _the-i 5 .LILCO Plan, how that plan was organizedi.and you mentioned 6 that your review was conducted in, the context of the transitic n 7 Phase, I think was your term. 8 What did you mean when you said, ' transition 9 phase.? to A It is my. understanding that that is a term that 11 is provided that is used to characterize the plan under ( 12 which LILCO would use the LERO organization. 13 Q What is the transition? ) 14 A Presumably to the time when offsite personnel -- 15 offsite agency personnel would assume other parts of the function. 16 l 17 Q You are talking about in the event of an actual l 18 emergency -- 19 A -- possibly, or -- i 20 0 -- when LILCO personnel performed duties, and ( when other offiste organizations came in to perform those 21 r 22 duties? O i I k l . ~ _ _ - _ _ - - _
= 64 1 A The norm in emergency planning is that states '2 and counties provide support to a utility. It is not my 3 te rm. .,3 4 I didn't_ originate it. I was just using it because 5 that is on the cover of the plan. - e 0 Let me assure you, Ms. Goodkind, if there is 7 one thing this case 'is, 'it is not the normal. Let me ask 8 you. You said you were retained approximately three weeks 9 ago. And you have given me a list of documents that you to have generally reviewed since you were retained. 11 In the course of ' preparing for this deposition, O' t a 12 have you 'done anything other than reviewed the documents that 13 you listed for me earlier, and I suppose had discussions with l 14 counsel. 15 A Well, I have mentioned discussions I had with Mr. 16 Aidikoff. There are other emergency planners in our 17 organization. People I work with, and I discussed with them s 18 some general concepts or FEMA position on various aspects. } t. 19 0 Th11 me what concepts or other FEMA positions \\ i 20 Tou have discussed with personnel? V 's 21 A Well,. for one thing, when I was at the post I exercise informal briefing at Quad Cities at the end of 22 f . O O j 1 e i i m
l l 65 AV 1 August, the FEMA representative from FEMA VII stated that 2 FEMA was using a number -- percentage number to estimate how many people would show up at a reception center. if you 3 4 made an announcement to the general public that they could come, or should come to a reception : center. 5 0 That number' is twenty percent? 6 7 A I haven't seen the memo. That was the question 8 I was asking and discussing with various people. I checked g through FEMA guidance memoranda and other memos that I have from FEMA, and did not find that in my notes. go Q Have you reviewed any deposition transcripts? 11 A No. 12 0 Have you reviewed any transcripts from hearings 13 34 -- previous hearings in this proceeding? A No, I don't believe so. 15 Q And other than your conversations with Mr. Behr 16 17 and Mr. Aidikoff and counsel, have you had any other 18 conversations or meetings with respect to your retention 19 as an expert for LILCO? A No. I had a telephone conversation with Ms. 20 Monaghan regarding my availability. 21 2-B 22 Q Have you reviewed all the contentions that have O
.. ~ 1 l-66 O been filed by the governments in this case? 1 2 A I reviewed the -- I have a set of contentions 4 dhat I believe are all the contentions. There are fifty 3 L ~ 4 some. I don't remember the: exact number. MS. MONAGHAN: Let me represent for the record 5 that Ms. Goodkind has.been given the December 4th. version 6 of the contentions. 7 8 BT MR. MILLER,: (Continuing) 9 Q Have you read or reviewed all the contentions? A Yes, I have.. go Q It is my understanding that you will be providing 11 testimony just on Contention 50, is that ' correct? 12 A That is my present understanding, and everything 13 else that. is exhumed or subsumed. 34 Q However you want to characterize it. 15 MS. MONAGHAN: I think the word used is, 16 ' subsumed.' 17 BY MR. MILLER: (Continuing) 18 19 Q Were you asked to review other contentions to l see whether you would render an opinion on any contentions 20 other than Contention 50? 21 22 A I was asked to review other contentions, because
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67 ) 1 Contention 50 cites so many other contentions. 2 Q Are you saying you were asked to review the contentions cross-referenced in: Contention 507 3 4 A Yes. 5 0 Were you asked to review any contentions other than Contention 50 with~ respect to rendering testimony, or 6 7 possibly rendering testimony on LILCO's behalf? 8 A There was some passing -discussion of some other 9 areas, perhaps. Say, on my experience with full exercises, i 1 to compared to partial exercises. That was the only other area that was discussed. it 12 Q That would be Contentions 15 and 16 you are 13 referring to? 14 A Yes, I believe that is right. 0 Were you asked to render an opinion on those 15 l contentions? l 16 17 A No. 18 Q When you say there were some discussions regarding i 19 those contentions, do you know why it is at this time you 1 20 will not be rendering an opinion on those contentions? 21 MS. MONAGHAN: Let me object to that question l 22 to the extent the question calls for you to repeat any O
68 O conversations which you may have had with me or with other 1 2 attorneys from Hunton & Williams, I would instruct you not to answer. To the extent.you can answer the question 3 based on your own-impression of why you have not been asked 4 to render testimony on that contention, you may answer the 5 question. 6 THE WITNESS: I don't 'have any particular-7 knowledge on which to answer. 8 BY MR. MILLER: (Continuing) g Q In your opinion, was the February 13th exercise. 10 a full scale, full participation exercise? 11 'A Yes. 12 0 I would ask what it is you based that opinion 13 14 upon? A Well, for one thing, at the very outset of the 15 FEMA Post Exercise Assessment, there is a discussion of l 16 17 two options that may be selected for the exercise. 18 If I remember,words in Option Two, there is the 19 word, ' full,' I believe. Full activation and participation. i I don't remember the words exactly, but I believe those 20 21 words appear in Option Two, which was selected. j 22 I think the other thing is -- although I don't O l
69 ,y i \\_/ 1 see a real definition of full participation exercise, I know what a limited participation exercise is, because I 2 have been at a number of them. I know what a limited 3 participation exercise is, because I have been at a number 4 f them. and I didn't see at this exercise what I have seen 5 at limited participation exercises. 6 Also, I guess the third factor might be that 7 I note that FEMA provided 38 evaluators for this exercise, 8 which certainly is typical of a full exercise. I have seen 9 exercises where a FEMA evaluator, where there were as few 10 as 11 FEMA observers. 11 7-(,/ Q Ms. Goodkind, simply because a statement is 12 rendered saying that the exercise should be a full scale la exercise, would that lead you to draw the conclusion that 14 it, in fact, was a full scale exercise? 15 A Well, I cited three factors. 16 Q I want to go through each one of the three. That g7 was my first question. gg l l 19 A Well, lets say that it was defined -- I would say the first statement indicates that this was designed as a 20 full participation exercise. l 21 1 22 Q Or it was supposed to be designed as such an
4 -70 1 exercise? 2 A All right. 3 0 Would you agree with me? 4 A Sure. 5 Q Now, the fact that there were 38 evaluators, or 6 whatever the number of evaluators, that doesn' t tell you that, 7 in fact,_ you have a full scale exercise either, does it? 8 A Well, I think we are working here' with a 9 situation that we are not starting with a definition of a l 10 full participation exercise. That is what I started out 11 saying. 12 And-you asked me in my opinion is this a full 13 exercise, and I would say that in all the aspects that I 14 examined, it appears to me the way a full participation 15 exercise appears. 16 Q Are you able to give me a definition of a full 17 participation exercise? A full scale exercise? 18 A Well, there would be, to me, a demonstration of 19 essential elements of protective actions, the actions that 20 are needed to protect the public. j 21 I don't believe there is a precise or agreed on 22 definition of what elements have to be tested. There is O I
71 G 1 discussion by FEMA of what constitutes, if you want to call 2 it, the core of an exercise. But that is not an official 3 FEMA position, so if your question is what does FEMA consider 4 a full exercise, I don't know that FEMA has informed anybody 5 of what that definition is. 6 If you are asking do I have a definition of a 7 full exercise, I guess I could tell you what my definition 8 would be, but I can't speak for FEMA. 9 Q FEMA's position, which is not an official position, 10 you are referring to FEMA Ex. 3, correct? 11 A Yes. (^T \\' '/ 12 0 Do you know if the NRC has an official position 13 as to what is a full participation exercise? 14 A It would be my feeling that that would be an 15 issue that the NRC would rely on FEMA to define. 16 Q Why don' t you give me your definition of what a 17 full scale exercise would be? 18 MS. MONAGHAN: Let me just state for the record 19 that as you know, Ms. Goodkind has not been asked to render 20 tes timony, as she s ta ted be fore, on either Contention 15 16, which deal with the issue of full participation 21 at 22
- exercise, n
b l
72 I am permitting your inquiry on this only 1 2 insofar as -it may deal with her background as a FEMA i. evaluator, and her knowledge of what FEMA does when it 3 evaluates an exercise. 4 You may answer the' question. 5 MR. MILLER: I am not going to. respond,_except-6 to say that I have various reasohs why I am entitled to ask 7 i 8 these. questions, including the fact that there have been 9 discussions between the witness and counsel as to the to possibility of rendering testimony on those contentions. ~ MS. MONAGHAN:. Mr. Miller, EI: just stated for the. 11 record that Ms. Goodkind is not, - at this time, going to 12 4 render testimony on Contentions 15 and 16. She has only 13 4 1 been asked to render' testimony on Contention-50. 14 MR. MILLER: It is, 'at this time,' that bothers 15 16 me. 17 MS. MONAGHAN: At this time, I don't anticipate 4 18 that that will change. 19 MR. MILLER: Ms. Goodkind, do you remember the 20 ques tion? THE WINTESS: You would like my definition of 21 22 a full participation exercise? (
73 1 -BY MR. MILLER: (Continuing). 2 Q Please. 3 A Well, the objective of an exercise is to show-4 that there in reasonable assurance that the public can be 5 -protected in the event of a radiation. accident. 6 So, I think there. are certain functions that - 7 are necessary to demonstrate that protective action could 8 be carried out. 9 Part of that is the organizational ability, I-10 think', ' organization' 'is probably the key. A great many 11 resources exists in this country to deal with emergencies ~% 12 and evacuations,- but because of the nature of a potential 13 nuclear plant reactor, it 'has been a decision in this country 14 to develop an organizational response that can provide prompt protection. 15 16 I think an exercise that demonstrates essential 17 elements of that would demonstrate full participation. The 18 capability to communicate with plant site, the ability to 19 get information to the public in the immediate vicinity. 20 I, myself, would say the capability of making 21 some assessment of what the radiation levels are, although 22 I note in _ this area FEMA itself has put that down to what -O ~
F 74 i they call a Category Bi so I think there is some difference 2 of opinion as to what constitutes essential functions. .It is a somewhat difficult issue, because. in 3 a full participation exercise, no one expects that every 4 element of NUREG 0654 is going to be demonstrated, and 5 certainly it is an important, significant factor that one 6 of those elements might -be. omitted from an 'ex' rcise, and e 7 it could still be a full exercise. 8 9 FEMA who has really developed the' philosophy of this, expects exercises 'to select among those elements Emd rotate 10 through them as they advise ' now, on a six year period. 11 C\\ \\d So, I kind of talked around it, but I think it 12 is easier to define what isn't full participation, where you 13 have some part of the emergency response organization 34 declaring at the outset that they are not going to activate 15 16 all of their capabilities. 17 It is typically seen where you have EPZ that 18 includes two states, and one s tate, such as Illinois, which e,* has (Ch11 reactors, of ten decides not to fully participate I 19 20 in every exercise. But when they share the EPZ with another 21 state, they may support that state by saying: We will staff 22 all our telephones, and we will receive all the messages you ,G l (_/ I
75 CE) t send us, and we will simulate the whole rest of our. 2 emergency capability. 3 And that is easily defined as limited partici-4 pation on their part. 5 Q Of the ten exercises or so where you have been either an evaluator or a controller, how many of those would - 6 7 you say have been. full participation exercises? 8 A I believe that allaof them had full participation 9 by at least one state. 10 Some of them, for instance, the D.C. Coo l 11 exercise, that actually was. a :small scalei exercise, FEMA's l ~ 12 term, so it is my recollection of that case that the county ~' i is participated fully, and the State of Michigan, which also 14 has several reactor sites, participated to a limited i 15 extent. 16 Q When - you say that most of ti a exercises, one of 17 the states participated fully, are you telling me that it 18 was not a full participation exercise? 19 A D. C. Cook 20 Q No, with respect to the others. If there is more than one state who has a response role, and only one state 21 22 participates fully, is that still considered a full O
76 .<^s U 1 participation exercise in your opinion? 2 A Well, I think FEMA considers that a full 3 participation exercise for the state. States have certain 4 requirements to exercise, so if that state fully participates 5 they get the credit from FEMA for a full exercise. 6 0 Ms.' Goodkind, have you done anything to prepare 2 7 for the upcoming hearings - :let me break-- that down. Have 8 you begun the process' of preparing testimony? 9 A. Only to a very, very limited extent. I have discussed with Ms. Monaghan some concepts for testimony, the: 10 11 direction the te'stimony may go. (.~) 12 0 Have you had discussions with anyone 'other than 1 13 Ms. Monaghan in that regard? 14 A To a very limited extent, perhaps, with Mr. 15 Zeugin. 16 0 Anyone other than counsel for LILCO? 17 A No. 18 Q Have you actually begun the process of drafting i ~ 19 your testimony? l 20 A I have not, no. 21 Q Do you know the other persons who, at this time, 22 have been designated by LILCO to testimony on Contention 50?
77 O 1 A I' have seen a list of people from Ms. Monaghan. 2 Q Now, other than Mr. Behr, who.I-believe is on 3 Contention 50, have you met with any of these other people, 4 or had conversations with.any of these-other people? 5 (Witness confers with her counsel) 6 A Mr. Purcell. 7 Q When did you have a conversation.with Mr. Purcell? 8 A Over dinner. 9 Q A week ago, a day.ago? 10 A A day ago.. 11_ Q Yesterday was a good day for.you, wasn't it? 12 (Laugh te r. ) 13 Did you and Mr. Purcell discuss your testimony 14 on Contention 50? 15 A No. 16 Q Did you discuss anything about Contention 50? ) 17 A Not that I recall. 18 Q It must have been a pleasant dinner. Other than l l 19 Mr. Behr and Mr. Purcell, do you recall any other meetings 20 or conversations with any other persons who have been 21 designated by LILCO to be witnesses on Contention 50? 22 A No. i
78 e 1 Q Have you, at this time, performed any research 2 or analysis which relates to Contention 50 -- or may relate to Contention 50 in the testimony you may offer? 3 A I have accumulated some past information regarding 4 ther exercises in which I have been an evaluator and/or 5 controller. 6 7 Q Can you tell me the kinds of information you have 8 accumulated? g A I have obtained copies of executive summaries of exercise assessments for a number of stations where I was 10 an observer. That is primarily what I have done. I have 11 ( reviewed again FEMA guidance memoranda. 12 Q Okay. Let me go back to this accumulation of 33 information. For the exercises that you have attended as 14 an evaluator or controller, you have gathered together the 15 e cube smades h Mose e m cises? 16 A Yes. Various materials. Typically, executive 37 summaries. In some cases gotten the scenario or the 18 l ob ective. That is primarily what I have accumulated. 19 Q What is the purpose of this task that you are 20 l performing in terms of accumulating this material? 21 22 A I anticipate my testimony may make some comparison AN]
79 p t ,) I to what was observed at the Shoreham exercise. What I 2 have observed at exercises I had attended in the past. 3 Q In that regard, how would exercise scenarios help 4 in the making of that comparison? 5 A Well, it seems to me that at the Shoreham exercise, 6 events moved very quickly at the onset of the exercise. In 7 other words, it would seem to me that the scenario moved 8 quickly into general emergency, and if you criticize people 9 for their performance, I think you need to keep some kind of 10 view of realities and ask yourself are some of the problems 11 that we are seeing artifacts due to the scenario or as we (~'/ i 's-12 discussed previously, may be due to simulation. 13 It is just trying to gather some information to 14 make the best assessment that you can, what kind of 15 performance was demonstrated. 16 So, I have looked back at other exercises to 17 see how much time transpired, for instance, between an 18 alert stage site area emergency, general emergency. 19 Q At this point other than accumulating the various 20 materials from other exercises you attended, have you begun 21 the process of making a comparison? 22 A No, not really, t' !u
- 80 1-Q Are you ; performing, or have you performed, any 2
other research or analyses in connection with Contention 50 t 3 other than what you have just described? 4 A No. 5 0 And I gather you have prepared no reports at this time? 6 7 A That is true. 8 Q Are you able to tell me the exercises Chat you 9 are gathering these materials -- from: which you are gathering ~ to these materials? 11 A I have gathered materials "from certain past 12 exercises. Again, these are generally the exercises that 13 I attended. There were four in Region II, at Ginna, l 14 Indian Point, Oyster Creek, James Fitzpatrick, all in 1982. I have some follow-on information from Indian I 15 l 16 Point in subsequent exercises. l 17 I have some information on exercises that I Cooh/ and LaSalle Station, and k 18 attended in Region V, D. C. 19 in Region VII, Oconee and Vogel in 19 86. l And then two Quad Cities exercises, 1985 and 20 l l 21 1986. I don' t have the 1985 material, but I have 19 86. Cook / and 22 Q Do you recall the years of the D. C. J O \\ l l i i ,,r-.,
4 F 81 0 LaSalle exercises? 1 2 A I believe it is 1982. 0 And is it fair to say you are primarily focusing 3 on gathering the material. from those parts of the exercises 4 you had some responsibility for evaluating? 5 A For instance, I mentioned I was - gathering 6 executive summaries, primarily. Information on how the 7 8 exercise was designed. In most cases my role as. an evaluator was at g either state or county EOC, so that encompassed quite a 10 i number of functions that were being directed out of the EOC. 11 0 Have you ever had responsibility for -evaluating 12 i any FEMA. exercise, any field activities? 13 14 A Any what? Q Any field activities?- 15 A Yes. 16 17 0 What would these field activities have been? A Evaluating radiological teams, field teams. 18 I 19 Q Anything else? A No, I think that is the only time I have been 20 assigned out in the field, and that was only on one 21 22 occasion. l
g 82 ,m ( 1 Q At this time, are you aware of any research 2 projects or analyses.which'~are being performed, or have been performed,'. by other LILCO witnesses on Contention. 50? 3 A No. 4 7 0 You were not at the February 13th exercise, is 5 that correct? 6 7 A I was not. 8 0 What is your degree of familiarity with.the LILCO 2 9 training program at this point in time? A-At the present time I am only f amiliar with 10 11 the frequency of the training, the way the staff are rotated - through thel training, and the types of materials in general 12 i that are used. I know there are. audio-visual materials, and g3 work books instruction. g4 0 Have you seen _the actual materials at this time?' 15 A No. 16 g7 Q Do you intend to review any of the LERO training 18 materials prior to rendering your testimony? 19 .A Not in any depth. There is a citation to one L specific section of-procedures within the. contention.. I plan 20 to lcok at that. 21 22 Q Do you recall which procedure you are referring to? l l 1 m..,
N 83
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A-5.1. Opip is the reference. in Contention 50. 2 LQ But in terms /of documents such 'as training 3 drill reports, or drill scenarios, or video tapes, work 4 books, lesson plans, things of that sort, -do.you believe you 5-will be reviewing those materials prior to rendering your 6 testimony? 7 A-I don' t think so. 8 Q Are you prepared to say, then, that you will be 9 basing your conclusion about the adequacy of' the LERO 10 training program primarily upont the FEMA Post Exercise 11 Assessment Report? 4 12 A Well, I -!think that will be' an important source 4 13 of information. I think there is relevant information from ~ 1 14 other sources. I don't think the FEMA Report gives much of an 15 I 16 indication of how many people are being trained, or even t 17 how many people who were fielded during the exercise.. 18 So,.I think the information that is given in the 19 Report, combined with some other information, will be used.. i 20 Q Do you think it is relevant to determine commenting l 21 upon the adequacy of LERO's training program how many people LILCO actually fielded on the day of the exercish? 22 O
84 /~T U-1 A Well, I think'it is pertinent when you are 2 looking at performance of individuals. The way the FEMA 3 Report had to be written, they cite -instances when. something 1 4 didn' t work properly, but I think if you are going to look 5 at the adequacy of the training, you also have to try to get for how many times things did' work properly. MN some 6 7 Q You are well aware that during exercises FEMA 8 only looked at a sampling of personnel in various areas, g correct? A Yes. 10 11 Q And we. have already. discussed bus drivers. During the Shoreham exercise, FEMA choose approximately ten bus 12 13 drivers for the Shoreham exercise, and looked at those 14 ten. Do you believe that if LILCO had another one 15 16 hundre d, two hundred, three hundred bus drivers attend the 17 exercise that were not evaluated by FEMA, that you could draw 18 any conclusions about the adequacy of the training of those 19 other bus drivers? A Well, I think you can draw some conclusions by 20 l 21 comparing the way that LERO fielded people for this exercise j 22 compared to what happened at some other exercises where the O
85 ,f (_ i exercise was structured such that one bus may be used for 2 simulation and one driver, and people who are organizing 3 the exercise know what bus that is going to be, and they 4 know who the driver is going to be. They have been through, 5 perhaps, many FEMA evaluations. They are familiar with FEMA evaluation modules. 6 7 It is easier to ensure a good performance of 8 that bus driver, but perhaps not as realistic. 9 I feel what LERO did was - provide a very realistic 10 demonstration of resources, and I think the grading that 11 they got by FEMA has to be put somewhat in that perspective. 12 Their people were not trained to provide a FEMA 13 response, but were trained to complete a function. 14 Q Do you have any information or knowledge about 15 the extent of training LERO had been offering to its 16 personnel since approximately 1983? 17 A hell, I know the training schedule. I have been 18 told the traiaing schedule that is used for people, and 19 the concept of the three shifts, and the fact that they are 20 doing quarterly training, and that individuals would expect 21 to have training on slightly more than an annual basis. 22 Q Are you aware of the fact that prior to the O()
86 .h,,, ~ 1 exercise in December and January, LERO held a number of-2 dress rehearsal drills, utilizing the personnel that would - be at the exercise?. 3 ~ 4 A I don't really know the details about that. 5 Q I was a little confused, because you seem to be telling me that during the Shoreham-exercise LERO personnel 6 7 were forced to participate in a more realistic setting 8 because they haven't had the opportunity to prepare -from the 9 standpoint of going through training drills and so forth? 10 A It wasn't exactly what I was trying to say. There were more people fielded by LERO for this exercise than I 11 have ever seen fielded in' any other exercise. 12 13 Q And, therefore, more persons ' for FEMA to choose 14 from to make their evaluations? l 15 A Yes. I think it.is a more realistic demonstration d 16 than when you are able to closely control the individuals 17 whom FEMA would be able to interview. 18 Q And you believe that at other exercises, FEMA 19 exercises you have attended, the persons being evaluated were able to control those persons FEMA was evaluating 20 4 21 more so than LILCO was able to do at its exercise? 22 A By virtue of the fact that not nearly as many 4 vy---v.- -w, 4 ..,-4 ,-,,my -,v, cy ir-. -_.-s-. ,w,,--,~..,_wm,-m-.e%.- ---e r.n-,-----
87 ~' i people were assigned roles. And also I think you have 3-A 2 to remember this was the first FEMA-graded exercise for 3 these individuals. 4 Q That is why I asked if you were aware how long 5 LILCO had been practicing for this exercise. 6 A I am not really aware of that, but it is my 7 impression that Ebis was the first FEMA-graded exercise. 8 Q Let's go back to the bus driver example. If 9 during the exercise FEMA looked at eight bus drivers, and to four demonstrated some insufficiency of performance in some 11 way, and yet there are approximately three hundred bus (~) drivers, would you assume that the other two hundred and 12 13 ninety-two bus drivers would have performed adequately if 14 they would have been chosen by FEMA? 15 A I wouldn' t necessarily make that assumption, but j 16 on the other hand, there were three staging areas for bus 17 drive rs, and I believe that FEMA's evaluation really found 18 no problems out of two of the three staging areas. 19 Now, perhaps, there is a problem since all the 20 bus difficulties arose from one staging area. I don't know i l 21 that is a contributing factor, but maybe we have a problem 22 at one of the staging areas. That could be one conclusion. ('T (/
88 r (s)/ ' The only thing I am saying is that you can go 1 2 to'some exercise at another facility where you have a bus 3 company under contract to you, and 'you arrange for a bus. 4 to make a demonstration during the exercise, which I feel 5 is typical. 6 It is easier to ensure a good performance, but 7 less sure in a real situation that you would be able to put 8 three hundred and fifty bus drivers with similar abilities 9 into the field. We need to keep perspective of what is the 10 real. situation. 11 The real situation in an emergency 'is 'that LERO 12 would be putting a large number of bus drivers into the 13 field, and I think in other exercises it is rare that you 14 staff all the bus drivers. 15 0 That is what I am trying to explore -with you in 16 .part. Is it your understanding that at o'ther FEMA-graded 17 exe rcises, the participants have some prior knowledge as to - 18 whom would be selected for evaluation by FEMA? 19 A Only by virtue of the fact that they have a smaller 20 number of participants. 21 Q So, maybe instead of calling out three hundred 22 bus drivers, you have twenty-six bus drivers called out? O u
89 i esI} 1 A Or five bus drivers. 4 2 Q But there are still some randomness to the 3 sampling by FEMA in terms of-determining. who is going to be 4 evaluated? 5 A If you are demonstrating with a sample of two 6 bus drivers, you are no longer worried about the randomness 7 of the situation. Both of those bus drivers are. going to be a very well trained. 9 Q And you have attended exercises where two bus 10 drivers were the only two called out? 11 A Well, I may be doing some comparisons like that rm 12 in the future, but just.from my initial involvement, I _ have 13 never seen such a large force fielded at an exercise. 14 Q That -- the problem I am having is that I am 15 trying to understand why the numbers standing alone impress l 16 you? 17 A Because it is more realistic. 18 Q And that is your opinion notwithstanding the fact 19 that far and away most of those numbers were not observed 20 or evaluated by FEMA in any way? i' I 21 A Well, it is still my belief that FEMA stated that 22 bus drivers were well trained, and performed well. So, I O
s 1 90 b<m ,I think that is impressive when you are talking about atforce x > 2 of three hundred mui sixty bus drivers. You are talking about 3 a sample of somewhere in another exercise where they field 4 two bus drivers, and those two bus drivers ' are very b" i 5 well trained. It is certainly more impressive. ' i 6 0 I believe we had this discussion before, I feel. 7 Are you aware that FEMA characterized bus drivers performance 8 as a deficiency? 9 A There were -- as I recall, there were two 10 deficiencies that related to training. Two instances. I feel the~ instances dhat were cited fer training were limitsd 11 12 in scope, s 13 Q One 'of those training instances would have been 14 the bus drivers? 15 A They indicated there was a need for more training 16 of bus drivers. I don't think that a statement that bus 17 drivers need more training is equivalent to saying that s a 18 bus drivers didn't perform well. 19 Q But it is your recollection from the FEMA Report i 20 that FEMA concluded that the bus drivers performed well? l 21 A Yes. aC i 22 Q And if I ask you again, for purposes of this O i l
91 1 deposition to assume with me that of the eight' general 2 Population bus drivers FEMA observed, three were found to 3 have significant problems in performing their duties. What 4 would that tell you, if anything, about the training that had been provided to those bus drivers? [ 5 ~ A Are you saying that is what FEMA said? 6 7 Q I am saying assume ' that. Assume wha't I am-saying s 8-is, in fact, the case. FEMA looked at eight. And three of s 4j~g j, 9 the eight just didn't perform well. What would that tell 10 you about the training for the bus drivers? 11 A Training by its nature is an. on-going activity, ~ ' ~ and even if a person performs a hundred percent of their. ~ 12 L. 13 duties perfectly 'during an exercise, you still going to come to the same conclusion, that all those bus drivers l', 14 need training again within the. next year. 15 s' And I think the conclusion from Chis exercise 16 17 is that bus drivers need additional ' training,. and they need 18 some better procedures. I that conclusion can be made from 19 what FEMA said in the exercise. 1 I don't think anyone is arguing that bus drivers 20 don't need additional training, but I do feel that overall 21 E the performance. of LERO bus drivers was good, and that 22 O ,k
N i J 92 ()- 1 mistakes that were made, for instance, where a bus driver missed part of a route, the bus driver doesn't operate in 2 3 a vacuum, and presumably in a real' event 1if something like 4 that happened there may be another recourse. We are talking 5 about a very big ' organization. 6 Q Ms. Goo dkind, I am not sure.,we are connecting 7 here. I;3m;asking a hypothetical. Something that has a lot .1' ..i 8 of basis if. fact from my review of the FEMA Report, but you ~ 4 9 can assume it is hypothetical. This is Mike Miller's-hypo- [ 19 10 thetical. There are three hundred.LERO bus drivers. Eight (>. 11 of those bus drivers are evaluated by FEMA at the Shoreham 12 ~ 3 13 exercise. Three of those eight bus drivers don't perform 14 well. They do something wrong, like they get lost, or they ~ .i /. 15 go to the wrong place. 16 If that is the case, in fact, that three of the 17 eight did not perform well according to FEMA, is it nonethe-18 less your opinion that you would draw the conclusion that 19 the bus drivers have performed well? 20 A Well, I would say with those conclusions, given 21 the hypothetical things that you have asserted, it is easy j 1 22 to conclude that the bus drivers need more training in order (
l 93 /7 V 1 to do their jobs better. 2 0. Would you conclude, given my hypothetical, that 3 the-bus' drivers performed well? 4 .A Well, you have~ to look at what was. their major 5 job? 6 0 Their job was to drive their buses, and to follow 7 particular routes to get to particular places. 8 A Well, I think one of the things that was cited 9 by FEMA was that a bus driver didn't read his dosimetry. 10 That bus driver probably performed well, but there is still 11 need for some training. rm 12 0 Okay. I am not talking. -- that is not. my 13 hypothetical though, i 14 A That was one -- 15 0 No, not for purposes of my hypothetical. My 16 hypothetical was you have eight bus drivers. looked at, three 4 17 do not perform well, and they do not perform well you can 18 define to be they went ' to the wrong place, or they drove the 19 wrong routes, or they got lost. Something of that nature. 20 I am not talking about not looking at dosimetry. 21 Would you draw the conclusion, under that 22 hypothetical, that notwithstanding all that, the bus drivers O i 4 i .,,m..-m,_,__.- _.,,__..y,__ m.
94-1 performed well? 2 MS. MONAGHAN: I am going to object to the 3 hypothetical. 4 MR. MILLER: It couldn't be any more clear. 5 MS. MONAGHAN:. The objection stands as to. the 6 hypothetical being vague. .If Ms. Goodkind can answer the 7 hypothetical, or respond to your question in the way it 8 was phrased, she may do so. 9 THE WITNESS: I find it kind of confusing, 10 . because we haven't discussed what the task was for the 11 driver and what the things were that they did wrong, and 12 how that-affected their overall assignment. \\~ 13 MR. MILLER: Ms. Goodkind, if you can ' t1 answe r 14 my question, that is fine. But we have discussed every 15 single one of those issues. 16 We have discussed the fact that the task was to 17 drive a bus to a particular place along a particular route, 18 and we have discussed that what they did wrong was that they 19 did not drive those routes correctly, or they got lost, or 20 they went to the wrong place. 21 That is my hypothetical. If you can't answer the 22 question, fine. ( )' i.
95 ~ U) l 1 THE WITNESS: I think I would prefer not to. 2 MR. MILLER: Lets take a break. 3 (Whereupon, a recess was taken at 4:05 p.m., to 4 reconvene at 4 :20 p, m., this same day.) 5 BY MR. MILLER: (Continuing) 6 Q Ms. Goo dkind, other than your accumulation of 7 materials from other exercises, at this time do you anticipate 8 performing any other kinds of research or analyses in 9 . connection with Contention 50? 10 A I don't know for sure what kind of comparisons 11 or research I may get into. I haven't thought of anything (' 12 other than the things I have mentioned at this time. 13 Q Do you have a copy of the Contentions with' you? 14 A Yes. 15 Q I ask you to turn to Contention 50, which begins is on page 87. I think we have established that at this time 17 you anticipate testifying on all of Contention 50, including 18 all the subsumed contentions within that contention, 19 correct? 20 A Yes, I believe that is correct. 21 Q Is it possible for you at this time to tell me 22 what you believe the thrust of your testimony will be l'^s U
96 on Contention 50? .g A Yes. I think ~ my testimony 'will demonstrate that 2 based on the materials I h' ave reviewed that the training 3 4 program was quite effective, and the' training in.the exercise 5 showed many instances where ~ activities were-well -executed, 6 and it showed that there has been ef fective training in 7 most instances, and I think my testimony will' draw some 8 comparisons between this exercise and other exercises. 9 Q Ms. Goodkind, let me ask you a general question 10 in that regard. Why do you consider it relevant what has 11 been done at other exercises from a training standpoint? 12 A Well, FEMA observers ~ were the ones who graded 13 this exercise, and I feel-that most FEMA evaluators do 14 a conscientious and thorough job of evaluating,: and their OP nions generally are valuable to me whatL they see and i 15 16 comment on training. 17 I am attempting to make some comparison to factors 18 in this exercise and factors in other exercises that FEMA ~ 19 has evaluated because there are some differences in the 20 Shoreham exercise, and I think there may be some comparisons h 21 that would be valuable between what FEMA observed here, and l 22 what FEMA has said at other exercises.
97 1 We are talking particularly about training,.and 2 based on my sampling of the eight exercises in which I was 3 an evaluator, I' have seen by looking back through the 4 assessment that FEMA.has recommended' additional training 5 at every one of those exercises. Now, the question that I may be looking.at is 6 7 are the citations that have been made by FEMA at the Shoreham 8 exercise a need for training above the norm of what FEMA has 9 recommended at other exercises. 10 That might be, for example, one of the types of-11 comparisons that might be made. 12 Q Are you saying that if FEMA always recommends 13 additional training, that the fact that. at the Shoreham 14 exercise FEMA also recommended additional training doesn't mean as much in terms of conclusions that could or should 15 be drawn? 16 17 A Well, I think there has been some interest in 18 whether the LERO participants is better than one would 19 expect, or worse that one would expect. It seems to me 20 that this is one of the things that we are looking at, t 21 and in order to answer that question, it may be interesting 22 to look at emergency personnel in general, and how do they ) l
~98 O 1 perform after. training. 2 It is usual that people demonstrate that they need 1 3 additional training. 4 Q To your knowledge,1 there has never been an example or instance of FEMA-graded exercise where FEMA did not 5 conclude that some ' additional training is needed? 6 7 A Well, I went back to my experience where I was 8 an evaluator, and based on the documents that I recited 9 earlier that I had looked at executive summaries and so on, 10 it is my recollection that when I looked through all of those that FEMA cited the need for more training at each 11 12 of those exercises. 13 Q Now, are you aware as to whether any-of those 14 exercises involved training issues which rose to the level 15 as being characterized as a deficiency by FEMA? 16 A I don't know the answer to that off hand. 17 0 Would you agree with me that at the Shoreham 18 exercise, at least two training related issues, that is 19 traffic impediments and bug drivers, rose to the level 20 of being characterized as deficiencies by FEMA? 21 A I think that two -- if I can rephrase, I think 22 it is the same thing you said. I believe that two of the ( i 1 i
99 deficiencies noted by FEMA have training aspects. 1 2 0 If the other eight exercises you participated 3 in as an evaluator, of those other eight, none of the 4 training issues raised by FEMA rose to the-level of being 5 a deficiency, would that lead you to draw any conclusions about the adequacy ' of the LERO training program at Shoreham? 6 7 Given FEMA's characterization of these two issues as 8 deficiencies at the Shoreham exercise? 9 A I don't think it is necessarily one-to-one 10 comparison. I feel that the deficiencies that were noted 11 at Shoreham may have involved something other than training.. 12 And training is broad, and it is something that contributed 13 to the deficiency. It might have been a combination of 14 equipment and training, or a conbination of procedures.and 15 training, and given the subjectiveness also of these kind 16 of evaluations, I know for certain that something that 17 occurs during one exercise sometimes is graded positively, 18 and you could have.the same action take place at another 19 location, and another evaluator would grade it another 1 I 20 way. 21 So, given the subjective nature of these things, l, 22 I don't think you can compare totally numbers to numbers, and O
i, 100 /*\\U 1 letters of deficiencies to deficiencies, without looking 2 at more detail. 3 Q If that is the. case, Ms._Goodkind, why is it you 4 are making _this comparison? 5 A Well, I am not going to compare strictly on 6 numbers at Shoreham, and numbers at other facilities. But _v I am saying that looking at other exercise evaluations may 8 contribute something to my testimony. 9 Q And at this time you are just not sure what, 10 if anything that comparison will contribute, _ is that 11 correct? 12 A Well, I have not started _ draf ting my testimony, so it is difficult for me to know-right now what role that 13 14 kind of comparison would play. 15 Q Do you think it is fair for one to say that in the instance of a deficiency or an area requiring. 16 17 corrective action, or for that. matter an area requiring 18 improvement noted by FEMA constitutes in some way a 19 training problem? 20 A No, I don't think one could say that. 21 Q Other than your opinion that you believe you 22 will testify as to the adequacy of the LERO training program, (:)
p 101 'is there anything else' you can tell me about what you 1: 4 anticipate your testimony will be on ContentionE50? 2 -3 A I; think my testimony.will be discussion of the ~g 4' many instances in which the LERO organization demonstrated the effectiveness of their training. 5 6 Q Juul would that be based primarily again upon. the 4 7 FEMA. Report? I 8 A As one of the major inputs. 1 9 Q Can you give me an example? 10 A Of what? i 11 Q Of an instance of where LERO performed.well from ( ~ 12 a training perspective, in your opinion? 13 A Yes. I think at the LERO EOC, you see that FEMA makes numerous citations of things that work very well 14 15 at the EOC. I ' think they use.the word, ' excellent' in J~ 16 there. They talk about implementation of procedures. I think if you look through the summary discussion 17 i 18 you see both the words, ' e xcellen t, ' and, 'well trained. ' 19 Q Is it your ' opinion that those areas where LERO performed well indicate that the LERO training program i 20 l 21 succeeded and is adequate? 22 A Well, as we discussed before, training is ( i 4 h v v w.--w,-#,..
102 1 on-going. 2 I think it shows that good training was done. 0 Are you telling me, Ms. Goodkind, that instances 3 4 where LERO performed well, in your opinion, would support 5 a conclusion about the adequacy of the LERO training program, but instances where LERO did not perform well would not 6 7 necessarily support conclusions regarding the inadequacy of 8 the training program? 9 A Well, I think the discussions we had about times when they, perhaps, didn't perform well have been so general in that what I am trying to say is that the citation of things 11 O(-) that they didn't do well on were not always related to their 12 primary function, so it is difficult to say because there 13 34 was a citation that they did something incorrectly, that it was a failure of training when they were still able to 15 carry out the overall function. gg g7 And, as far as the significance of mistakes that 18 were made, I think you also have to look at the effect the 19 action that was taken. For instance, with the radiological dose assessment, there were a couple of mistakes that were 20 made. There was a decimal error, and there were some other 21 i 22 errors in managing the data. A) (_
i l ( 103 ' /"s - Q). 1 It is my feeling that those kind of mistakes 2 are typical, and perhaps even come with a guarantee from -3 the evaluations that I have done of radiological assessments. 4 If you in the confusion and the flow of data, if you don' t 5 get something reported as a rem, that is a mil) ' rem, and k t 6 Vice versa at some time during the accident, than probably 7 the simulation isn ' t realistic ' enough. 8 And that is why I feel that most plans are' set 9 up wi'th a redundancy as this plan is, where you have people 10 making an assessment at the onsite organization, and one at 11 the-offsite organization. But the point here I am trying to 12 make is that some mistakes were made along the way to 13 radiological assessment, but the radiological assessment 14 function at the EOC was well carried out. 15 And even though mistakes were made, I don't think if anyone is even making a contention that the Brookhaven organization is not well qualified and well trained. 17 i 18 I would think that most' people -- I could be 19 mistaken -- but I feel they give a very strong support, and 20 that given their intensive training, and so on, that they 21 are very well qualified. 22 Neve rtheless, some mis takes were made. But the ^ L
- ~ 104 D 1 1 overall assessment was. effectively carried;out,-and the 2 protective action was properly recommended. - And, FEMA has 3 noted all of these things as well'as the fact =that a 4 evacuation was'well managed from the EOC. s Q And in your opinion, therefore,.you can reach the l 6 Conclusion that the training program has been adequate? l 7 A I'think I will be, in my testimony citing- ) 8 instances that demonst' rate good performance of people who i 9 have been trained, i f to Q Based upon primarily the FEMA report? 11 A Yes. I think there needs to be some-perspective (:3-j 12 brought if you are going to try to answer the question of F i 1 13 whether training is achieving some results. - You need to. i 14 not only look at citations of things that went wrong, but l l 15 you need to look.at those things and attempt to put them I-16 in perspective. 17 Did they affect overall performance? Were they 18 due to other factors? If you are going to look at 1,200 l-19 people being trained, I think you want to try to get some 20 indication of good performance as well as mistakes. 21 Q One of the sub-parts of Contention 50, Contention 22 27, is on Page 93 and alleges that there has been no trainins !(:)
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105 (_) I given to school bus drivers in the areas of dosimetry and 2 other related areas. 3 Do you believe that training in such areas as the 4 use of dosimetry, radiation exposure, is necessary with 5 respect to the LILCO plan for personnel such as school bus 6 drivers? 7 A If bus drivers are going to be used, I think they 8 should be given some training. 9 Q Would your answer be the same with respect to 10 outside organizations such as the ambulance and the ambulette 11 companies? 12 A If they are not sufficiently trained for the 13 function they would provide in the emergency, then I think 14 they should be trained. Is Who does it might be a different question. And 16 personnel have different training programs of their own. 17 Q Do you have any basis for disagreeing with the 18 allegation that LERO's response to two traffic impediments 19 demonstrated serious communications failures within LERO? 20 A Is that contention written here? 21 Q Well, this is my rough paraphrase of Contention 22 45 which begins on Page 95. It's all kinds of detailed O
106 ,en s i examples of that. 2 A Well, it says here serious communications failures a played a major role in LILCO's inability to remove the 4 impediments. s Q Do you have any disagreement with that statement? 6 A Yes, I would disagree with that. We've-talked 7 about some things that happened with the free-play which kept 8 it from being very realistic. 9 And I think the fact that route spotters were to available and a truck was dispatched that had radio capa-11 bilities to call for additional equipment as needed; you ()- 12 know, the fact that a lot of equipment wasn't dispatched 13 immediately is mitigated by the fact that you have someone 14 there with equipment who can request additional assistance. 15 So, I don't know that the communication failures le which, as I understand them, were mainly up the chain of 17 command really would have affected removal of the impediment. 18 Q When you referenced just now the lack of an 19 immediate response to the impediments, you are aware that 20 there was in the nature of a two to three hour delay in 21 responding to the impediments? 22 A I know there was delay. And, I think one -- I O
107 G 1 think there were some contributing things to the delay 2 which we have already discussed. One of them is where the 3 free-play message was inserted so that a portion of the time 4 was spent in trying to confirm in the field that this impe-5 diment existed, which is where a message-like this in a real 6 case would originate, from the field, s 7 So, there was a period of time there. And, then 8 due to the simulation there was some difficulties in match-8 ing up with the FEMA person which, I believe, contributed 10 more to the delay. 11 And, there were some glitches, I would say, in 12 the handling of the situation. 13 Q Which is by LERO personnel? 14 A Yes. 15 Q Does that tell you anything about the adequacy 16 of training? 17 A Well, I think that LERO has acknowledged that if you are going to assume that a very major impediment like 18 18 this really could occur, then it probably would be well to 20 provide their people with some additional training. 21 And, it's my understanding that they have already gone ahead and conducted that kind of training. Then, in 22 O
108 (~'i L/ 1 fact, I'm sure that the exercise event in itself was -- it 2 provided very significant training opportunities for the players. 3 Q I think we have discussed this before, but are 4 you aware of the fact that there has been the same sorts of 5 problems incurred by the LERO personnel with respect to 6 traffic impediments simulated during post-exercise training 7 drills? 8 A I don't know that. I haven't seen those drills. 9 Q And if, in fact, that is the case does that tell 10 you anything about the adequacy of the LERO training pro-11 gram? O! 12 A Well, again we talked about the fact that I'm 13 not sure everything was in place that they had intended 14 during that drill. You know, I think one of the basic 15 questions we had here was whether the emergency workers 16 need to be trained extensively to respond to this kind of 17 incident. 18 And my understanding is that LERO has decided 18 to provide this kind of training. Whether it should receive a great deal of emphasis or not, I'm not sure. I haven't 20 21 been party to all the discussions of it. Q From other exercises you have been involved with, 22 [vD
.e -109 () 1 .Ms. Goodkind, are you aware of anywhere FEMA noted one or -2 more deficiencies? 3 A I haven't looked at the exercises from that ~ stand-4 point. I'm really'not prepared now to talk about it. 5 I wouldn't want to mention a deficiency of one a that had occurred at a different location. I remember a 7 number-of citations where -- since I'm particularly focusing 8 on training, I remember reviewing certain exercises where 9 training was strongly emphasized as an area of need.- to Q I'm just talking about deficiencies of any kind. 11 Are you aware of any where there was one or more deficiencies i 12 noted? i la A I haven't really looked at that specifically. i 14 Q' Are you aware of any exercise, FEMA exercise, 15 where one or more deficiencies were noted and FEMA did not f 16 require a remedial exercise thereafter? i i 17 A Well, you know, since I really couldn't answer the la first part of the question, I can't -- l 19 Q I'm asking with respect to any exercise, not just ( 20 the ones you have attended? I 21 A I can't recall at present a specific instance when [ 22 i O l r
= 110 ysb 1 FEMA has ordered er not ordered a remedial exercise. 2 Q Do:you understand the-concept of the remedial 3 exercise? ) 4 A .Yes', I believe so. If FEMA feels there is enough 5 doubt in terms of reasonable assurance, which is the term e that they use, that the public can be' protected and they 7 -feel there is sufficient urgency in providing that reason-8 able assurance, they could request a remedial exercise. 9 And, I know that one of the guidance memoranda 10 addresses the criteria for remedial exercise, end3A 11 Q From your perspective as one who has been involved () 4 l. 12 in planning and training issues for-the last 10 or 15 years, 13 your resume'says, given the fact that FEMA noted five, at 14 least five, deficiencies at this exercise, do you believe l 15 that there should be a remedial exercise for the Shoreham 16 plant? 17 A I'm not an expert on what constitutes the need for l 18 remedial exercise. But, based on my experience and the fact 19 that LILCO will be required to exercise again anyway, the 20 issue of remedial exercise almost becomes a moot question i l 21 because subsequent exercises will be required anyway, at 22 least on a bi-annual basis. So, we know that there will be () i
111 . () 1-follow-on exercises. 2 Q Well, keep in mind, with Shoreham.you.have at 3 . issue now whether or not there should be an' operating' 4 license issued -- 5 A - Yes. 6 Q -- and that there is a regulation which requires 7 a FEMA-graded exercise to be conducted prior to the issuance 8 of such a license. And there has now been such an exercise 9 conducted. 10 Do you believe that there should be a remedial 11 exercise held by FEMA and performed by LERO personnel prior O 12 to the-issuance of an operating license for the Shoreham 13 plant? 14 A I would have to say not necessarily. I know there 15 are some issues such as siren testing which would need to 16 be looked at. 17 I feel there are some other things that could-18 perhaps be verified by FEMA. It's not uncommon for FEMA to grade exercise portions and special drills separate from a 19 20 full exercise. I don't know enough about FEMA's procedures 21 to know if this might be an option. 1 22 But I know at other exercises FEMA has graded O k ..r- .--,...~.~,.,9_s_.,p- ... ~.....,_ ,.....,4_mm..-.__.m.~,,, _...,__n,.__ r,.__,,_-__ .__-,,,,#-.-_.cr
112 v 1 ' activities on.a day before the exercise'~or.a day after the 2 exercise. And.to require LERO to commit the resources as 3 they did for this exercise again, to address a limited 4 ' number of items, it appears.to me from the RAC review that 5 they found that the procedures and revisions.that have been 6 offered by LILCO have been found to adequately address the 7 issues that were brought up by the exercise. And there are 8 only a couple that are still outstanding items-thay are 9 awaiting signed agreements. 10 Now, I know that they have said these things need 11 to be' retested. And, that is certainly the case. O 12 But, the question of whether they justify a-13 remedial exercise when we know there will be other exercises 14 in the future, it would seem to me not necessarily required ui to go through a full-blown exercise to test those four or-16 five deficiencies, one of which was evidently an equipment 17 problem'at the ENC which seems as though it has been very 18 thoroughly resolved by LERO by their commitment to a new 19 facility with a lot of redundant copying equipment. 20 Q Do you agree that there should be a demonstration of the ability to provide reasonable assurance of the public' 21 s 22 health and safety prior to the issuance of a commercial O
113 ~ 1-operating license for nuclear power plants?~ 2 A Yes.- '4 3 Q Do you agree with me that FEMA makes,that 4 - determination through the' conduct of exercises? 5 A Yes. 6 Q Are you aware of how FEMA has defined-the term 7 " deficiency" in the context of the Shoreham exercise? 8 A Well, I'm not aware that they define it particu-larly in context of the Shoreham exercise, but I know that: i 9 4 10 it has been defined by FEMA in general. 11 Q Are you aware that the definition of the term 0 " deficiency" is that there can be no conclusions reached as 12 13 to the. reasonable assurance of the public's health and 14 safety? 15 A I don't know that I would have paraphrased it 16 exactly in that way.- The definition is available here to 4 17 both of us. 18 Q How would you define the term " deficiency?" 19 A I would define it the same way FEMA has. I mean, 20 it's a FEMA term. 21 Q I'm looking for the definition in the report to i 22 make sure that we have a common understanding. Okay. On O 1 e, n - --+ --.+-ww ve.nm.---mm-- ,-w w ---,,-,-.-----,n. ,-w- ~,.r-.- r-, e s --
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114 h 1 .Page 8 of the. report, it.says - - 2 MS. MONAGHAN: Would you like to have Ms. Goodkind a furnished with a copy of the report so that she can look at 4 the definition also? 5 MR. MILLER:.That's fine. Page 8. s (The~ witness is provided with the document.) 7 BY MR. MILLER: (Continuing) 8 Q " Deficiencies are demonstrated.and observed in-1 9 adequacies that would cause a finding that off-site emergency 10 preparedness was not adequate to provide reasonable assurance 11 that appropriate protective measures can be taken to protect O 12 the health and safety of the public living in the vicinity 13 of the nuclear power facility in the event of a radiologi-14 cal emergency." 15 And that's the definition of " deficiencies" as 16 used by FEMA in the Shoreham exercise report. Okay? 17 A Yes. 18 Q Now, given that definition and given the fact that 19 there were, I believe, five deficiencies noted by FEMA, is 20 it your opinion that the Shoreham plant should be licensed i 21 without the necessity of requiring a remedial exercise before 22 hand? ( j .. _. - _ _,. _.,, _ _ _. _, _,. _,. ~,. _,
115 O '/ 1 MS. MONAGHAN: I'm going to object to the question 2 on the grounds of the competency of the witness to answer 3 whether or not FEMA ought to be making a reasonable assurance 4 finding based on the' statements made in the post-exercise 5 assessment for Shoreham. 6 You may answer the question if you can. 7 THE WITNESS: No. I don't think that I'm in a 8 position to make a statement on that. 8 BY MR. MILLER: (Continuing) 10 Q From a training perspective, you don't believe 11 you are in a position to make that statement? 12 A That's true. 13 Q And that's because you agree with Ms. Monaghan 14 that you are not competent to address this issue? 15 A Yes. 16 MR. MILLER: I think I'm through with my question-17 ing, but I have two matters that I will address to Ms. 18 Monaghan. 19 First of all, we have requested numerous times 20 about whether or not LILCO will be providing training i 21 materials since the production that was made I think around 22 October 29th, including the drills from December of 19867 l V O l
116 s (_) 1 Can you tell me at this time whether this material 2 will be provided? 3 MS. MONAGHAN: Mr. Miller, LILCO is in the process 4 and Hunton & Williams' attorneys are in the process of 5 gathering those materials together specifically to produce 6 them to you. At this time, there has not been a report 7 issued for the December drills. 8 We will provide that report to you when it is 8 issued. Due to the snow situation in the Washington and to Richmond areas, we have been delayed in collecting those materials and getting them to you as soon as we had antici-11 ( 12 pated that we would. 13 But my understanding is we are going to try to ship them out to you tomorrow. And that will be responses 14 15 to the requests that were made in the depositions of Mr. 16 Daverio, Mr. Weismantle and Mr. Behr. 17 MR. MILLER: Okay. Thank you. Now, today we had mentioned by Ms. Goodkind those materials that she has 18 gathered, or perhaps is still in the process of gathering, 18 20 from other exercises she attended. And I would, at this time, request production by counsel for LILCO of those 21 documents that have been accumulated and are being accumulated 22 l a
'l f 117 O 1 by Ms. Goodkind. ~ 2 MS. MONAGHAN: We will take'your request under 3 advisement. Certainly, we will provide the. documents that 4 are'available'that indicate the~~ exercises at which Ms. 5 Goodkind has been an evaluator. 6 But, to the extent that the materials that she 7 pulls together are with the evaluation and concurrence and 8 selection of counsel, that. production will be denied as 9 work product. 10 MR. MILLER: With respect -- I didn't quite under-11 stand that last part. 12 MS. MONAGHAN: To the extent that materials other 13 than materials from exercises at which she was an evaluator 14 are selected and gathered and reviewed by Ms. Goodkind, 15 that would be on the basis of the work product decision-16 made between Ms. Goodkind and her counsel and those will 17 not be provided. 18 MR. MILLER: Well, if I recall -- maybe I should go back and ask Ms. Goodkind, but I understand that the 19 20 materials that she is pulling and has accumulated are 21 materials that were from these other exercises, such as 22 the executive summaries and the scenarios and objectives and
\\ s. 118 g ~ 1 things of that nature. 2 MS. MONAGHAN: To the extent that that is the case, 1 3 I will Provide you with the materials that she has gathered 1 4 that relate to the exercises which she observed. 5 BY MR. MILLER: (Continuing) 1 6 Q Ms. Goodkind, at this time are you gathering 7 together or accumulating, or have you accumulated, any s 8 documents of any other kind? 9 A No. 10 Q Do you intend to do so? 11 A I don't know. I don't have any intention now. ,a E, h 12 MR. MILLER: I have no further questions. 13 MS. MOFACHAN: I have no questions. 14 MR. CUI9 TING: I have no questions. 15 MR. MILLER: Thank you, Ms. Goodkind. 16 THE WITNESS: You are welcome. 17 (Uhcrcupon, the taking of the deposition was concluded 18 at 5:00 p.m., this same date.) 19 }{Q ({p [j Om mc 20 lhiskd;y of dM4-f , 19 / '/. MAIt? GgKIND 411[J? &%.yh n'L 1)x4y Puolic 22 M/ Commi.;cien 6pges 'f- U*Pa l n k.) ,s
i -q t \\1 119 w) I is CERTIFICATE OF NOTARY PUBLIC AND COURT REPORTER \\ g. 2 3 I,. Garrett J. Walch, Jr.,;the officer'before whom 4 the foregoing deposition was taken, pages 1 through 118, do s hereby certify that the witness whose testimony appears in Ny 6 the foregoing deposition was dulyssworn by me; that the e i. i d. 7 testimony of said witness was taken by me and thereafter \\ ^ i.3 ' 8 reduced to-typewriting by me'or under my direction; that 9' said deposition is a true record of the testimony given by 10 the witness; that I am neither counsel for, related to nor 11 employed by any of the parties to the action in which thin A# 12 deposition was taken; and further, that I am not a relative f or empioyee of any attorney or counsel employed by the 13 s 14 parties hereto, nor financially or otherwise' interested in 15 the outcome of the action.
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16 / 17 GARREff J. HALSH, JR. 18 Notary Public in and for the 19 Commonwealth of Virginia at Large 20 il My Commission Expires: January 9, 1989 22 1 k 9 ..L _.1__,...~.
h Y /f/p d MARY E. GOODKIND !O EDUCATION H.S., Radiological Health Physics, i Northwestern University H.B.A., Economics. Northwestern University I B.S.
- Zoology, Unive,rsity of Michigan PROFESSIONAL EXPERIENCE Hs. Goodkind has fifteen years of consulting experience in environmental and safety areas.
Radioloalcal Emeroency Plannina Exnerience Ms. Goodkind has radiological emergency planning experience that includes: I exercise evaluation as a Federal Emergency Hanagement Agency (FEMA) observer; development of emergency plan procedures and training; O exercise participation as a controller. Hs. Goodkind has also assisted FEMA with preparation of interim findings reports, as a consultant to Argonne National Laboratories (ANL). Her emergency planning experience has included exercise evaluation, control, and training in the following areas: State and County Emergency Operation Centar functions, i field team activities, radiological dose assessment, prompt alerting and notification, early dismissal of school students, decontamination and relocation center operations, medical drills, and recovery and re-entry. Ms. Goodkind is the author of a training module on radiological physics prepared for exercise evaluators at the U.S. Department of Energy (US00E) and has i presented seminars on radiological emergency planning for the US00E and for ANL. Ms. Goodkind has participated in ten radiological emergency exercises as an evaluator or controller. 'O .w.-.-. -.,,,.,. - ~. - - ---r
MARY E. G000 KIND q Page Two O PROFESSIONAL EXPERIENCE Other Evnerigaca (cont'd) Ms. Goodkind has conducted environmental radiologic monitoring programs at seven nuclear power stations. She has also performed offsite dose assessment, in-plant shielding calculations, and specification of radiation detection equipment. She served on an advisory committee on low level radiological waste disposal for the Illinois Atomic Energy Commission. Ms. Goodkind is a past president of the Midwest Chapter Health Physics Society and of the Chicago Section, American Nuclear Society. Ms. Goodkind has been an expert witness on environmental issues in the states of Illinois and Kentucky. 5 CERTIFICATIONS Ms. Goodkind is a Certified Safet Certified Hazard Control Manager.y Professional and a She is also trained in management of hazardous chemicals and in m hazardous waste site remediation. She is a contributing author to the National Safety Council on a hazardous material guidance manual. PROFESSIONAL AFFILIATIONS American Society of Safety Engineers Society for Risk Analysis National Coordinating Council on Emergency Management Health Physics Society American Society of Civil Engineers O l = - - = m m= -w --v}}